Specific tariff entries control exemption: imported raw silk was not covered by the mill yarn surcharge exemption.

Imported raw silk was treated as a separate commercial commodity from mill yarn (all kinds) under the Karnataka Sales Tax Act scheme, because the statutory schedules assigned distinct entries and different tax treatment to raw silk, silk yarn, and raw silk imported from outside the country. The court applied the principle that a specific entry prevails over a broader one and that schedule items must be understood in trade parlance. On that basis, the surcharge exemption confined to mill yarn (all kinds) could not be enlarged by implication to cover imported raw silk, so the exemption was denied.

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Issues: Whether imported raw silk fell within the expression "mill yarn (all kinds)" in the exemption notifications issued under section 8-A of the Karnataka Sales Tax Act, 1957, so as to qualify for surcharge exemption.

Analysis: The goods in question were separately dealt with in the statutory schedules: raw silk and silk yarn imported from outside the country were covered by one entry, mill yarn (all kinds) by another, and raw silk including raw silk yarn and silk yarn imported from outside the country by a further entry. By creating distinct entries and assigning different tax treatment to each, the Legislature treated them as separate commercial commodities. In taxation, a specific entry must be given effect to in preference to a broader or similar entry, and items in the schedules must be understood in the sense in which they are known in trade. The exemption from surcharge was extended only to mill yarn (all kinds), and could not be enlarged by implication to include raw silk imported from outside the country.

Conclusion: Imported raw silk did not fall within "mill yarn (all kinds)" and was not entitled to surcharge exemption; the issue was answered against the assessee and in favour of the Revenue.

Final Conclusion: The challenge to the denial of surcharge exemption failed because the statutory scheme treated raw silk and mill yarn as distinct taxable goods, and the exemption could not be extended beyond the specific entry covered by the notification.

Ratio Decidendi: Where goods are separately classified under distinct schedule entries, an exemption notification confined to one specific entry cannot be extended by analogy or implication to another separately classified commodity.

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