Specific tariff classification governs combined refrigerator-freezers with separate doors, excluding the household refrigerator entry and exemption benefit.

Combined refrigerator-freezers fitted with separate external doors are to be classified under the specific tariff entry for combined refrigerator-freezers, because the heading terms and product features, including separate compartments and functional parameters, answer that description directly under General Rule 1. The more general household refrigerator entry cannot prevail, and there is no occasion to apply Rule 3(c) when a specific heading fits the goods. On that classification, the goods fall under CTH 84181090 and do not qualify for the exemption under Notification No. 85/04-Cus.

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Issues: Whether combined refrigerator-freezers fitted with separate external doors are classifiable under heading 8418 10 90 as combined refrigerator-freezers, or under heading 8418 21 00 as household refrigerators, and whether such classification entitles the importer to the benefit of Notification No. 85/04-Cus dated 31-8-2004.

Analysis: The product literature showed separate refrigerator and freezer compartments, separate external doors, distinct capacities, and different functional parameters for refrigeration and freezing. The tariff itself separately enumerates combined refrigerator-freezers with separate external doors, household refrigerators, and freezers, which indicates that these are distinct entries for classification purposes. Under the General Rules for Interpretation, classification must first be determined according to the terms of the headings. Since the goods answer specifically to the description of combined refrigerator-freezers fitted with separate external doors, Rule 1 applies directly and there is no occasion to resort to Rule 3(c). Even on a classification comparison, the more specific description is the combined refrigerator-freezer entry, not the general household refrigerator entry. The Board's circular, though not binding, supported this view and clarified that such goods fall under sub-heading 8418.10 and are outside the notification benefit.

Conclusion: The goods were correctly classified under CTH 84181090, and the exemption under Notification No. 85/04-Cus was not available.

Ratio Decidendi: Where goods are expressly described by a specific tariff entry, classification must be made under that entry according to the terms of the heading, and the residuary or later-heading rule cannot override a more specific description.

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