Specific tariff entry prevails over residuary classification for berseem seeds, confirming clover seed treatment under the tariff.

Berseem seeds imported from Egypt were held to fall within the specific tariff description of clover seeds under Heading 1209.22, rather than the residuary Heading 1209.99 for other seeds. The classification turned on the principle that a specific tariff entry prevails over a general or residual entry when the goods answer the specific description. The DGFT circular relied on by the importer did not override the clear tariff wording. The goods were therefore correctly classified under Heading 1209.22, and the claim for classification under Heading 1209.99 was rejected.

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Issues: Whether berseem seeds imported from Egypt were classifiable under Heading 1209.22 as clover seeds or under Heading 1209.99 as other seeds.

Analysis: The disputed goods were found to answer the description of clover seeds. The tariff specifically provided for clover seed under Heading 1209.22, while Heading 1209.99 covered only residual or other goods. In tariff classification, a specific entry must be preferred to a general entry. The reliance placed on the DGFT circular did not displace the clear tariff description applicable to clover seeds.

Conclusion: The goods were correctly classified under Heading 1209.22 and the importer's claim to Heading 1209.99 was rejected, in favour of Revenue.

Ratio Decidendi: Where a tariff item specifically describes the goods, classification must be made under that specific entry and not under a residuary or general entry.

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