Specific tariff entry prevails over general foodstuff classification for canned prawns under fiscal law.

Canned prawns were treated as the specific commodity "prawns" under item 65A rather than as "foodstuffs sold in sealed containers" under item 43. The Kerala HC applied harmonious construction and the popular, statutory meaning of fiscal entries, holding that a general entry cannot displace a specific one. Canning or sealing did not alter the essential character of the goods, so the levy based on item 65A was upheld and the challenge failed.

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Issues: Whether canned prawns fell within item 43 as foodstuffs sold in sealed containers or within item 65A as prawns under the Kerala General Sales Tax Act, 1963.

Analysis: The entry for foodstuffs is a general expression, while prawns are a specific commodity separately enumerated in the Schedule. In fiscal legislation, words are to be understood in their popular sense and in their statutory context. Applying harmonious construction, the general entry could not be read so broadly as to absorb the specific entry for prawns. Canning or sealing did not change the essential character of the commodity, which remained prawns.

Conclusion: Canned prawns did not fall under item 43 and were rightly treated as prawns under item 65A; the challenge to the levy failed.

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