Specific tariff entry prevails over general electronic goods classification for medical equipment, sustaining higher tax rate.

Medical electronic equipment such as neonatal intensive care incubators, neonatal care centres, infant warmers and phototherapy units were held to fall under the specific schedule entry for instruments and appliances used in medical science, including electromedical apparatus. The presence of micro-processors did not shift the goods to a general entry for electronic goods, because a specific tariff entry prevails over a general one where the goods answer both descriptions. The court therefore applied the medical instruments classification and upheld tax at 5% rather than 3%, rejecting the assessee's challenge.

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Issues: Whether the medical electronic equipment sold by the assessee was classifiable under the general entry for electronic goods or under the specific entry for instruments and appliances used in medical science, and consequently liable to tax at 3% or 5%.

Analysis: The goods were neonatal intensive care incubators, neonatal care centres, infant warmers and phototherapy units. Although each item contained a micro-processor, the relevant schedule contained a specific entry for instruments and appliances used in medical, surgical, dental or veterinary sciences, including other electromedical apparatus, and that entry did not turn on whether the equipment was electrical or electronic. A general entry for electronic systems and goods could not displace the special entry dealing with medical instruments. Where a specific entry covers the goods, it must be preferred over the general entry.

Conclusion: The goods fell under the specific medical instruments entry and were taxable at 5%, not 3%; the assessee's challenge failed.

Ratio Decidendi: When goods answer a specific tariff or schedule entry, that specific entry prevails over a general entry even if the goods also possess electronic components.

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