Specific tariff description prevails over general heading in classification of hot rolled stainless steel Patta/Patti.

Tariff classification of hot rolled stainless steel Patta/Patti turned on whether the specific heading for Patta/Patti prevailed over the more general heading for flat-rolled products. The analysis treated the named description in Heading 7219.30 as controlling, reasoning that later processing other than cold rolling did not move goods out of that entry where they already answered the specific description. The General Notes to Chapter 72 and the HSN Explanatory Notes supported the principle that a specific tariff entry by name overrides a broader one. The goods were therefore classifiable under Heading 7219.30.

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Issues: Whether hot rolled stainless steel Patta/Patti of width 600 mm or more was classifiable under Heading 7219.10 as flat-rolled products not further worked than hot-rolled, or under Heading 7219.30 as Patta/Patti when subjected to any process other than cold rolling.

Analysis: The product was specifically described as Patta/Patti in Heading 7219.30, and that description governed classification. The process words following that description did not mean that only processed goods could enter the heading; rather, Patta/Patti falling within the description continued to remain in that heading even if subjected to processes other than cold rolling. The General Notes to Chapter 72 and the HSN Explanatory Notes supported the view that further finishing treatments do not change the heading, and a specific entry by name must prevail over a more general one.

Conclusion: The goods were classifiable under Heading 7219.30 and not under Heading 7219.10.

Final Conclusion: The classification adopted by the lower authority was set aside and the assessee succeeded in the appeal with consequential relief.

Ratio Decidendi: For tariff classification, a heading specifically naming the product prevails over a more general heading, and subsequent processing does not displace classification where the product already answers the specific description.

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