Specific tariff entry governs taxation of imported tractor parts, attracting single-point levy over general multi-point assessment.

Imported tractor parts were treated as goods falling within entry 55 of the First Schedule to the Tamil Nadu General Sales Tax Act, because the imports were made under licences for agricultural tractor parts, customs duty was paid on that basis, and the bills and objections described them as tractor parts. The court found no reliable basis to restrict the goods to diesel-engine spare parts only. As the goods answered the description in the specific First Schedule entry, the special single-point levy under that entry applied and excluded assessment under the general charging provision in section 3. The revisions were allowed and the assessments restored in favour of the Revenue.

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Issues: Whether imported tractor parts, sold in some transactions as spare parts for diesel engines, fell within entry 55 of the First Schedule to the Tamil Nadu General Sales Tax Act so as to attract single-point tax, or whether they were liable to multi-point taxation under section 3 of the Act.

Analysis: The goods were imported under licences for agricultural tractor parts and customs duty was paid on that basis. The evidence also showed that they were treated in bills and objections as tractor parts. There was no reliable basis to hold that the goods could be used only as spare parts for diesel engines and not as spare parts for tractors. Where goods answer the description of a specific entry in the First Schedule, the special single-point levy attached to that entry governs the assessment and excludes resort to the general charging provision in section 3.

Conclusion: The goods were held to be tractor parts falling within entry 55 of the First Schedule and liable only to single-point tax under that entry, not to multi-point taxation under section 3. The revision petitions were allowed and the assessments were restored in favour of the Revenue.

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