Special provision prevails over general machinery entry: electrical and electronic goods were outside entry tax without a valid notification.

Electrical and electronic goods, including computers, could not be brought to entry tax as "machinery (all kinds)" for 1 April 1994 to 31 March 1997 because the operative notification during that period covered only machinery and did not specifically include that category. The earlier notification including electrical and electronic goods had been rescinded, and the later notification restoring that category took effect only on 31 March 1997. Applying the rule that a special provision prevails over a general one, the Court treated electrical and electronic goods as a distinct taxable category and held that a general machinery entry could not substitute for the missing notification.

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Issues: Whether computers and other electrical and electronic goods could be subjected to entry tax as "machinery (all kinds)" for the period 1 April 1994 to 31 March 1997, and whether the absence of a notification for electrical and electronic goods during that period barred levy of entry tax on such goods.

Analysis: The levy under the entry tax law was structured through notifications corresponding to the Schedule entries. The earlier notification covered both electrical and electronic goods and machinery, but it was rescinded and, from 1 April 1994, the operative notification covered only machinery (all kinds) and certain other specified items. A separate notification bringing back electrical and electronic goods came into force only on 31 March 1997. The Court held that although a computer may answer the description of machinery in a broad sense, the expression "machinery" is a general entry, while electrical and electronic machinery forms a distinct and special category. Where the legislature has treated electrical and electronic goods as a separate entry, the general entry cannot be used to impose tax on them. The principle that a special provision prevails over a general one was applied.

Conclusion: Entry tax could not be levied on electrical and electronic goods, including computers, for the period 1 April 1994 to 31 March 1997 in the absence of a valid notification covering that category.

Final Conclusion: The petitions succeeded to the extent that any entry tax, assessment, or penalty imposed on electrical and electronic goods for the period was liable to be quashed, while the assessing authority was left free to proceed in accordance with law on objections in pending matters.

Ratio Decidendi: Where the statute treats electrical and electronic goods as a separate taxable category, a general entry for machinery cannot be used to impose tax on that special category in the absence of a valid notification specifically covering it.

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