Specific tariff heading prevails over residual heading where ball bearing parts are expressly covered by HSN notes.

Goods described as parts and components of ball bearings, including needle rollers, cages, races and rings, were held classifiable under Heading 84.82 because the HSN explanatory notes expressly covered needle rollers, inner and outer races, and inner and outer rings. The specific tariff entry prevailed over the residual Heading 84.85, and no contrary indication in the Central Excise Tariff justified resort to the residual heading. The classification was therefore decided in favour of Revenue and against the assessee.

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Issues: Whether the goods described as parts and components of ball bearings, including needle rollers, cages, races and rings, were classifiable under Heading 84.82 of the Central Excise Tariff or under the residual Heading 84.85.

Analysis: The goods were found to be parts of ball bearings. The relevant HSN explanatory notes for Heading 84.82 specifically covered needle rollers, inner and outer races, and inner and outer rings. The classification exercise was required to follow the nomenclature indicated by the HSN, and there was no contrary indication in the Central Excise Tariff to exclude the goods from Heading 84.82. Since the goods were specifically covered by the tariff heading supported by the HSN notes, the residual heading was not available.

Conclusion: The goods were correctly classifiable under Heading 84.82 and not under Heading 84.85. The finding was against the assessee and in favour of Revenue.

Final Conclusion: The appeal failed because the disputed goods were held to fall within the specific tariff heading for ball or roller bearings, leaving no scope for resort to the residual machinery-parts entry.

Ratio Decidendi: For tariff classification, a specific heading supported by the HSN explanatory notes prevails over a residual heading where the goods are expressly covered and no contrary legislative intention appears in the tariff.

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