Specific tariff heading for relays prevails over railway equipment heading where the goods are ordinary relays.

Relays manufactured for supply to Indian Railways were held classifiable under Heading 8536.90, because that heading specifically names relays as electrical apparatus for switching, protecting and connecting circuits. Heading 8530.00, which covers electrical signalling, safety or traffic control equipment for railways, was not applicable since the record did not show that the relays, by themselves, constituted railway signalling or safety equipment. In the absence of documentary material proving a distinct railway-equipment character, the more specific tariff description prevailed over the broader railway heading, and classification was decided in favour of the Revenue.

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Issues: Whether relays manufactured for supply to the Indian Railways were classifiable under Heading 8530.00 as electrical signalling, safety or traffic control equipment for railways, or under Heading 8536.90 as electrical apparatus for switching, protecting and connecting electrical circuits.

Analysis: Heading 8536.90 specifically covers electrical apparatus for switching, protecting and connecting electrical circuits and expressly mentions relays. Heading 8530.00 covers electrical signalling, safety or traffic control equipment for railways. The goods in question were found to be relays, and the record did not establish that they were distinct from ordinary relays or that they, by themselves, constituted railway signalling, safety or traffic control equipment. The lower appellate finding that parts such as relays do not fall under Heading 8530.00 was accepted, and no documentary material was produced to displace that view.

Conclusion: The relays were not classifiable under Heading 8530.00 and were liable to be classified under Heading 8536.90. The issue was decided against the assessee and in favour of the Revenue.

Ratio Decidendi: Where a tariff heading specifically covers the goods by name, classification cannot be claimed under a more general heading meant for a different class of equipment unless the assessee proves that the goods answer that description on their own.

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