Specific HSN classification prevails for air bubble film rolls, which fall under plastic sheets, not packing material.

Air Bubble Film Rolls were held classifiable as polyethylene sheets under HSN 3920.10.92 because their commercial character and constituent material matched the specific plastic-sheet entry. HSN 3923, which covers articles for conveyance or packing of plastics, was found inapplicable since the product is used mainly to protect fragile goods and does not fall within the ordinary packing-material description in that entry. The specific HSN classification therefore prevailed over the broader packing-material or residuary treatment, and the authority's classification under HSN 3923 / Entry 103 of SRO 82 of 2006 was set aside in favour of the assessee.

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Issues: Whether Air Bubble Film Rolls are classifiable under HSN Code 3920 as poly ethylene sheets attracting tax at 4%, or under HSN Code 3923 / Entry 103 of SRO 82 of 2006 as packing material attracting tax at 12.5%.

Analysis: The commodity was examined by reference to its commercial description, its constituent material, and the relevant HSN structure. HSN Code 3923 covers articles for conveyance or packing of goods of plastics, but the listed sub-classifications did not correspond to Air Bubble Film Rolls, which are used only for protecting fragile goods and are not ordinary packing material in general. HSN Code 3920, on the other hand, covers plastic sheets, and the product was found to be a poly ethylene sheet with air bubbles, falling within HSN Code 3920.10.92. Since the commodity fits the specific classification under HSN 3920, the residuary or packing-material classification was held inapplicable.

Conclusion: Air Bubble Film Rolls are classifiable under HSN Code 3920.10.92 and not under HSN Code 3923 / Entry 103 of SRO 82 of 2006; the classification adopted by the authority was set aside in favour of the assessee.

Ratio Decidendi: Where a commodity can be specifically classified under an applicable HSN entry, that specific classification governs and a broader packing-material or residuary entry cannot be applied.

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