Tariff classification of cotton terry fabric favours the specific terry towelling heading over the general linen entry.

Grey cotton terry towelling fabric in running length was treated as classifiable under Heading 5802.21 because the tariff specifically covered terry towelling and similar woven terry fabrics of cotton, including goods not subjected to any process. Chapter 63 was confined to made-up articles, and the fabric in running length was not itself a made-up item; it became a towel only after further processing. On the tariff description, the specific entry for terry towelling fabric prevailed over the general linen heading. The classification under Heading 5802.21 was upheld, and Heading 6302.00 was rejected.

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Issues: Whether grey cotton terry towelling fabric in running length was classifiable under Heading 5802.21 as terry towelling fabric of cotton not subjected to any process, or under Heading 6302.00 as bed, table, toilet or kitchen linen.

Analysis: The disputed goods were cotton terry towelling fabric in running length, and the process of conversion into individual towels was not in dispute. Heading 58.02 specifically covered terry towelling and similar woven terry fabrics of cotton, including goods not subjected to any process, whereas Chapter 63 was confined to made-ups. The fabric in running length was not itself a made-up article; the towel became made-up only after further processing. On the tariff description, the specific entry for terry towelling fabrics was more appropriate than the general linen heading.

Conclusion: The goods were correctly classifiable under Heading 5802.21 and not under Heading 6302.00. The classification adopted by the Revenue was upheld.

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