Specific tariff entry prevails for bulk-imported Micronized Progesterone BP, preserving concessional customs benefit.

Micronized Progesterone BP imported in bulk was treated as a drug covered by Sl. No. 80(A) of Notification No. 21/2002-Cus because it was specifically named in List 3 under Sl. No. 58. The bulk form did not justify shifting the goods to the general bulk-drug entry in Sl. No. 80(B), as exemption entries must be construed strictly and a specific description prevails over a more general one. The concessional duty benefit therefore applied under the specific List 3 entry, and denial of that benefit on the basis of bulk import form was unsustainable.

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Issues: Whether Micronized Progesterone BP imported in bulk was classifiable under Sl. No. 80(A) of Notification No. 21/2002-Cus dated 01.03.2002 as a drug specified in List 3, or under Sl. No. 80(B) as a bulk drug used in the manufacture of such drugs or medicines.

Analysis: The imported product was admittedly Micronized Progesterone BP. The dispute turned on whether its bulk form excluded it from Sl. No. 80(A). The goods were specifically covered in List 3 under Sl. No. 58, and the relevant entry in Sl. No. 80(A) extended the concessional benefit to drugs, medicines, diagnostic kits or equipment specified in List 3. Following the earlier Tribunal view on identical notification entries, the description of the goods had to be construed strictly, and goods expressly named in List 3 could not be shifted to the bulk-drug entry merely because they were imported in bulk form.

Conclusion: The imported goods were eligible for classification under Sl. No. 80(A), and the denial of concessional duty under Sl. No. 80(B) was unsustainable.

Ratio Decidendi: Where a bulk imported product is specifically named in List 3 of a customs exemption notification, it is to be treated as a drug covered by the specific entry for concessional benefit, and not displaced to a general bulk-drug entry merely because of its import form.

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