Specific statutory classification prevails over residual entry in treating piston rings as declared goods, not automobile parts.

Piston rings manufactured from iron fell within the declared goods entry as "rings" under Section 14(iv)(viii) of the Central Sales Tax Act, 1956, so the specific central classification prevailed over the Punjab VAT Act's residual entry for automobile parts. The common parlance or use-based test could not displace an express statutory description where the goods were specifically named in the declared-goods schedule. On that basis, the Tribunal's classification was upheld, and the goods remained taxable as declared goods rather than as automobile parts. The revenue failed to establish any substantial question of law.

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Issues: Whether piston rings manufactured from iron were covered as declared goods under Section 14 of the Central Sales Tax Act, 1956, or were liable to be classified as automobile parts under the residual entry in the Punjab Value Added Tax Act, 2005.

Analysis: Piston rings were specifically included in the declared goods entry as "rings" under Section 14(iv)(viii) of the Central Sales Tax Act, 1956. Where a product falls within a specific statutory entry, the general or residual entry cannot be invoked merely because the goods are also used as automobile components. The common parlance test does not displace a specific entry when the statutory language itself provides the relevant description. The State schedule had to yield to the central declared goods entry.

Conclusion: The goods were correctly treated as declared goods taxable at 4% and not as automobile parts taxable at 12.5%.

Final Conclusion: The classification made by the Tribunal was upheld and the revenue failed to establish any substantial question of law.

Ratio Decidendi: A specific statutory entry identifying goods by description prevails over a general or residual entry, and use-based classification cannot override an express declared-goods entry.

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