Tariff classification of absorbent cotton wool and cotton carded follows specific heading text, not end use or retail-sale character.

Tariff classification of absorbent cotton wool and cotton carded must be determined first from the wording of the relevant headings and the interpretative rules, with specific tariff descriptions prevailing over broader or general entries. The Tribunal held that these goods were specifically covered by the headings relied on by the assessee, and that their use, packing, retail-sale status, end use, or medical character did not justify shifting them to Chapter 30. It further held that reliance on end-use considerations could not override the express tariff entries, and that the earlier coordinate decision on the same classification issue supported this approach. The demand was therefore not sustainable.

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Issues: Whether absorbent cotton wool and cotton carded were classifiable under the specific tariff headings for textile goods or could be shifted to Chapter 30 on the basis of use, packing, retail sale, and medical character, and whether Notification No. 30/2004-C.E. was inapplicable.

Analysis: The dispute turned on tariff classification. The Tribunal held that classification must first be determined from the terms of the headings and the relevant interpretative rules, and that specific descriptions in the tariff prevail over broader or general entries. It noted that absorbent cotton wool and cotton carded were specifically covered by the tariff headings relied upon by the assessee, and that their uses, packaging, end use, or IP grade did not justify exclusion from those specific headings. It further held that the revenue's attempt to place the goods in Chapter 30 by relying on end use and retail-sale notions could not override the specific tariff entries, and that the earlier coordinate decision on the same issue supported this approach.

Conclusion: The goods were rightly classifiable under the specific tariff headings claimed by the assessee, the demand was not sustainable, and the departmental appeal failed.

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