Specific tariff classification controls roofing tile tax treatment; residual entry cannot apply once goods fit the named category.

Tiles manufactured as roofing tiles were held to fall within the specific tariff description for roofing tiles other than country tiles, rather than the residual category for other tiles. The classification turned on whether the goods squarely fit Entry 8(iii) of Part T of the Second Schedule to the Karnataka Sales Tax Act; once that specific fit was established, extraneous considerations such as separate account books or the intended consumer class for decorative tiles were irrelevant. The operative effect was classification under Entry 8(iii) at 5%, not under Entry 8(iv) at 15%.

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Issues: Whether the roofing tiles and decorative roofing tiles manufactured by the assessee fell under Entry 8(iii) of Part 'T' of the Second Schedule to the Karnataka Sales Tax Act as roofing tiles other than country tiles, or under the residual Entry 8(iv) as other tiles.

Analysis: Entry 8 specifically classified tiles into distinct sub-entries and separately provided a residual category only for tiles not covered by sub-entries (i), (ii) and (iii). The assessee's goods were found to be roofing tiles, and the tax authorities themselves had accepted that they answered the description in sub-entry (iii). In a taxing statute, the decisive consideration was whether the goods squarely fit the specific entry; extraneous considerations such as separate account books or the High Court's view about decorative tiles being meant for a different class of consumers were irrelevant once the goods were otherwise shown to fall within the specific tariff description.

Conclusion: The goods were covered by Entry 8(iii) and were taxable at 5%, not under Entry 8(iv) at 15%.

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