Gold ornaments with imitation stones fall under specific tariff entry, not the residuary entry.

Ornaments of personal wear made of gold or silver, or a mixture of both, remained within item No. 3F where they were studded only with imitation stones, engraved with mina, or otherwise did not contain the specified precious stones. Item No. 28, which applied to jewellery set with precious stones and real pearls, had no application on those facts. Item No. 67 operated only as a residuary entry and could not be used where the goods squarely fell within a specific item. The ornaments were therefore covered by item No. 3F and excluded from item No. 67.

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Issues: Whether the sale of gold ornaments studded with imitation stones or engraved with mina, but without precious stones, fell under item No. 3F or item No. 67 of Notification No. 33927F dated 30th December 1957.

Analysis: Item No. 3F covered ornaments of personal wear made of gold or silver, or a mixture of gold and silver, unless they were studded with the specified precious stones. Ornaments studded only with imitation stones, engraved with mina, or otherwise not containing the enumerated precious stones remained within item No. 3F. Item No. 28 concerned jewellery set with precious stones and real pearls and had no application. Item No. 67 was a residuary entry and applied only when the goods did not fall within any specific entry. Since the ornaments in question squarely answered item No. 3F, the residuary entry could not be invoked.

Conclusion: The ornaments were taxable under item No. 3F and were not taxable under item No. 67.

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