Specific tariff heading prevails: bedding and furnishing articles of foam and quilting fall under Chapter Heading 94.04.

Reasonable opportunity of hearing was not denied where multiple personal hearing dates were granted but not availed, so the natural justice objection was rejected. For tariff classification, the specific description in Chapter Heading 94.04 prevails over the more general plastic and fabric headings; flexible polyurethane foam mattresses, pillows, bolsters and quilted fabrics were treated as bedding and similar furnishing articles covered by Chapter Heading 94.04, and classification under Chapter Heading 39.21 and Chapter Sub-heading 5806.90 was not accepted. The note also reflects the principle that the most specific tariff heading governs classification where the goods answer that description.

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Issues: (i) Whether the appellant was denied reasonable opportunity of hearing before the appellate authority; (ii) whether flexible polyurethane foam mattresses, pillows, bolsters and quilted fabrics were classifiable under Chapter Heading 94.04 rather than under Chapter Heading 39.21 or Chapter Sub-heading 5806.90.

Issue (i): Whether the appellant was denied reasonable opportunity of hearing before the appellate authority.

Analysis: The record showed that several opportunities of personal hearing were afforded to the appellant, but those opportunities were not availed. In such circumstances, the grievance of violation of natural justice could not be sustained.

Conclusion: The contention of denial of hearing was rejected and the point was decided against the appellant.

Issue (ii): Whether flexible polyurethane foam mattresses, pillows, bolsters and quilted fabrics were classifiable under Chapter Heading 94.04 rather than under Chapter Heading 39.21 or Chapter Sub-heading 5806.90.

Analysis: Chapter Heading 94.04 specifically covered mattresses, quilts, cushions and pillows, whether covered or not, and the HSN explanatory notes supported that understanding. The goods in question were articles of bedding and similar furnishing stuffed or internally fitted with material or of cellular rubber or plastics, and therefore fell under the specific tariff heading rather than the more general plastic or woven fabric headings.

Conclusion: The goods were correctly classified under Chapter Heading 94.04, and the classification under Chapter Heading 39.21 and Chapter Sub-heading 5806.90 was not accepted.

Final Conclusion: The appeal failed on both the hearing objection and the classification dispute, and the revenue's classification was upheld.

Ratio Decidendi: For tariff classification, the heading providing the most specific description prevails, and goods answering the description of bedding and similar furnishing under Chapter Heading 94.04 remain classifiable there even if they are not covered and even if they are made of polyurethane foam or combined with quilting materials.

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