Classification of electronic washing machines under the specific electronic entry prevailed over the broader electrical appliances entry.

Onida electronic washing machines were classified as electronic appliances under Entry C-II-97(b) rather than as domestic and commercial electrical appliances under Entry C-II-73(a), because the specific electronic entry governed over the broader electrical entry. The court relied on the earlier Supreme Court view that electronic washing machines are electronic goods and noted that Entry C-II-73(a) expressly referred to washing machines, while Entry C-II-97(b) covered electronic systems, instruments, apparatus and appliances not specified elsewhere. On that basis, the Tribunal's classification under Entry C-II-97(b) was sustained, and the issue was decided in favour of the assessee.

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Issues: Whether Onida electronic washing machines were classifiable under Entry C-II-97(b) of Schedule C, Part II as electronic appliances, or under Entry C-II-73(a) as domestic and commercial electrical appliances.

Analysis: The classification turned on the meaning of the competing schedule entries and the distinction between electrical and electronic appliances. Entry C-II-73(a) expressly mentioned washing machines, while Entry C-II-97(b) covered electronic systems, instruments, apparatus and appliances other than those specified elsewhere. The Court applied the earlier Supreme Court view that electronic washing machines are electronic goods, and held that the presence of a specific electronic entry governed the classification. On that basis, the Tribunal's view that the washing machine fell within Entry C-II-97(b) was sustained.

Conclusion: The washing machine was rightly held to fall under Entry C-II-97(b), and not under Entry C-II-73(a); the answer was against the Revenue and in favour of the assessee.

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