Specific tariff description prevails where imported goods retain the essential character of Sulphonated Fish Oil, defeating a broader classification.

Imported goods were correctly classifiable as Sulphonated Fish Oil under chapter sub-heading 34029020 because the department did not discharge the burden of proving a different classification. The chemical examiner's report identified the goods as preparations containing Sulphonated Fish Oil and additives, but did not specify the additives or show that they displaced the essential character of the product. Technical opinion on one product also supported its identity as Sulphonated Fish Oil. End use for fat liquoring could not override the tariff description unless the goods first fell outside that heading. Applying Rule 3(a) of the Customs Tariff Interpretation Rules, the more specific description prevailed over the less specific heading.

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Issues: Whether the imported products were correctly classifiable as Sulphonated Fish Oil under chapter sub-heading 34029020 or as preparations for oil or grease treatment under chapter sub-heading 34039100.

Analysis: The department bore the burden of proving the proposed classification. The chemical examiner's report only stated that the samples were preparations having Sulphonated Fish Oil and additives, without identifying the additives or showing that their nature and quantity displaced the essential character of the goods. The material relied upon by the department did not establish that the goods ceased to be Sulphonated Fish Oil. The technical opinion concerning one of the products described it as oil based on Sulphonated Fish Oil and also as a strong Sulphonated Fish Oil, which supported the assessee's classification. The end use for fat liquoring could not override the tariff description unless the goods first went outside the scope of Sulphonated Fish Oil. Under Rule 3(a) of the Rules of Interpretation of Customs Tariff, 1975, the more specific description had to prevail over the residuary or less specific heading.

Conclusion: The goods were correctly classifiable under chapter sub-heading 34029020 as Sulphonated Fish Oil, and the department's appeal failed.

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