Classification of dressed leather sheet soles favoured entry 12 over the footwear exclusion under entry 36.

Dressed sheets of hides and skins made from leather clippings and used as soles in footwear were held to fall under entry 12, which covered hides and skins whether raw or dressed, rather than entry 36, which applied only to leather goods other than footwear. Even if treated as leather goods, the goods formed part of footwear and were excluded from entry 36. Entry 12 was treated as the more specific classification, so the goods were taxable under that entry and not under entry 36, and the revision failed.

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Issues: Whether dressed sheets of hides/skins consisting of leather clippings used as soles in footwear fell under entry 12 or entry 36 of Notification No. F. 5(16)FD(CT)/69-2 dated 8th March, 1969.

Analysis: Entry 12 covered hides and skins whether raw or dressed, while entry 36 applied only to leather goods other than footwear. The goods in question were dressed sheets of hides/skins. Even if they were treated as leather goods, they formed part of footwear and were therefore excluded from entry 36. Entry 12 was the more specific and appropriate entry for such goods.

Conclusion: The goods were taxable under entry 12 and not under entry 36; the revision failed.

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