Specific tariff entry prevails for Xerox machines classified as duplicating machines, rejecting the lower-tax general entry claim.

A Xerox machine was treated as a duplicating machine because its ordinary and popular meaning, and its essential function, is to make copies of originals. Entry 12 of the First Schedule, which specifically covers duplicating machines, prevailed over entry 83, a general residual entry for machinery not otherwise mentioned. The argument that any ambiguity should be resolved in favour of the lower-tax general entry was rejected because the machine fell clearly within the specific description. Classification was therefore under entry 12 and not entry 83.

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Issues: Whether a Xerox machine is classifiable as a duplicating machine under entry 12 of the First Schedule to the Andhra Pradesh General Sales Tax Act, 1957 or as all kinds of machinery under entry 83, and whether any ambiguity required adoption of the lower-tax entry.

Analysis: The determining factor was the ordinary and popular meaning of the expression and the use to which the goods were put. A Xerox machine was held to be an instrument whose essential function is to make copies of originals, which answers the description of a duplicating machine. Entry 83 was treated as a general entry covering machinery not specifically mentioned elsewhere, while entry 12 specifically referred to duplicating machines. Even if the goods could be viewed as falling within both entries, the specific entry would prevail over the general entry. The argument based on alleged ambiguity and lower tax was rejected because the item was found to fall clearly within the specific description.

Conclusion: The Xerox machine was held to fall under entry 12 and not entry 83, and the dealer's claim for classification under the lower-tax general entry was rejected.

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