Specific tariff entry prevails over general vehicle-part entries in classifying bearings for motor vehicles and tractors.

In classification under a taxing schedule, a specific entry for identified goods prevails over broader entries describing vehicle parts or tractor parts by use or application. Bearings manufactured for motor vehicles and agricultural tractors were therefore classifiable under the separate entry for bearings, not under the general entries for motor vehicle parts or tractor parts. The tractor notification, which applied only to sales or purchases by registered dealers of specified tractors and their components, did not displace that specific classification, and its later exclusion of bearings reinforced that bearings were outside its scope.

---

---

Issues: Whether bearings manufactured for motor vehicles and agricultural tractors were classifiable under the specific entry for bearings or under the entries for vehicle parts and tractor parts with the relevant notifications.

Analysis: The entries in the sales tax schedule showed that bearings of all types were separately and specifically covered by the entry for bearings, while the vehicle-part and tractor-part entries were general in comparison. The notification for tractors specifically designed for agricultural use also applied only to sales or purchases by a registered dealer of such tractors and their components, parts and accessories. The Court held that where a taxing statute contains a specific entry for the goods in question, that entry overrides a broader general entry. The amendment to the tractor notification excluding bearings only reinforced that the notification could not govern the assessee's bearings.

Conclusion: The bearings were correctly classified under the specific entry for bearings and not under the entries for motor vehicle parts or tractor parts.

Ratio Decidendi: In classification under a taxing schedule, a specific entry for identified goods prevails over a broader general entry covering goods by description or use, and a notification applicable only to a distinct class of dealers or goods cannot displace that specific classification.

---