Specific tariff entry prevails over general vehicle-accessory entry, so tyres, tubes and flaps attracted the higher entry tax rate.

Tyres, tubes and flaps were held to fall under the specific 4% entry for those goods, not the broader 1% entry for motor vehicles and their parts and accessories. Even if such items can generally be treated as vehicle accessories, a separately enumerated commodity must be classified under its specific entry, which prevails over a general description. The notification was treated as clear, so there was no basis to invoke a dealer-favouring construction. The levy at 4% was therefore upheld and classification under the 1% entry was rejected.

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Issues: Whether tyres, tubes and flaps purchased for fitting in motor vehicles were liable to entry tax at 1% under the entry for motor vehicles and their parts and accessories, or at 4% under the specific entry for tyres, tubes and flaps.

Analysis: The tax notification issued under Section 3 of the Rajasthan Tax on Entry of Goods into Local Areas Act, 1999 separately prescribed a 4% rate for tyres, tubes and flaps and a 1% rate for all types of motor vehicles including their parts and accessories. Although tyres and tubes may generally be regarded as parts and accessories of motor vehicles, the goods in dispute were specifically described in a distinct entry. Where the commodity is specifically and separately enumerated, that specific entry prevails and there is no scope to shift it to a broader general entry. The notification therefore did not create any ambiguity warranting adoption of the dealer-favouring rule.

Conclusion: The specific entry for tyres, tubes and flaps governed the levy, and the 4% rate was correctly applied; the assessee's claim for classification under the 1% entry failed.

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