Poultry-feed classification turns on essential character and use, placing shell grit and mineral mixture under the specific tariff entry.

Shell grit and poultry-feed mineral mixture were treated as poultry-feed because their essential character and use, supported by expert material, showed they contained minerals such as calcium and phosphorous and were used in poultry feeding. The specific tariff entry for poultry-feed and cattle feed therefore applied, and the goods were not classifiable as general goods under the residual sales tax provision. The stated principle is that goods shown by their use and accepted expert evidence to fall within a specific entry must be classified under that entry rather than under a general or residuary description.

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Issues: Whether shell grit and poultry-feed mineral mixture were classifiable as poultry-feed under Entry No. 80 of the First Schedule to the Andhra Pradesh General Sales Tax Act, 1957, or liable to be treated as general goods under Section 5(1) of that Act.

Analysis: The items were found to be used by poultry and, on the basis of the expert material relied upon, were shown to contain minerals such as calcium and phosphorous and to be used as poultry-feed. The Court agreed with the Tribunal that the essential character and use of both items brought them within the specific entry for poultry-feed and cattle feed, rather than the general goods treatment adopted in revision.

Conclusion: Shell grit and poultry-feed mineral mixture were covered by Entry No. 80 of the First Schedule and were not liable to be classified as general goods under Section 5(1).

Ratio Decidendi: Where goods are specifically shown, on the basis of their use and accepted expert evidence, to fall within a particular tariff entry, they must be classified under that specific entry rather than under a general or residuary description.

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