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Issues: Whether multigrove surface silver and multigrove V/D silver were classifiable under entry 15(1) of Schedule E to the Bombay Sales Tax Act, 1959 as domestic electrical appliances, or under entry 7A of Schedule E as lamps or components, parts and accessories of lamps.
Analysis: Entry 7A specifically covered lamps, along with components, parts and accessories thereof. The articles in question were found to be sophisticated lamp shades designed to project concentrated light and therefore fell within the class of lamp fittings or parts. Where a specific entry expressly covers the goods, it prevails over a broader description such as domestic electrical appliances. The cited decisions on domestic electrical appliances did not assist because the real question was one of classification under the more specific tariff entry.
Conclusion: The goods were correctly held to fall under entry 7A of Schedule E and not under entry 15(1); the reference was answered in favour of the assessee.
Ratio Decidendi: For tariff classification under the Bombay Sales Tax Act, a specific entry expressly covering lamps and their parts, components and accessories overrides a more general entry for domestic electrical appliances.