Tariff classification for absorbent cotton wool must follow specific headings, with medical use and packing not shifting it to Chapter 30.

Goods expressly covered by the tariff headings for absorbent cotton wool and cotton carded must be classified under those specific entries, not shifted to Chapter 30 as wadding, gauze, bandages or similar medical-use articles merely because they are supplied to hospitals or bear medical packaging. Classification must follow the terms of the headings and sub-headings; use, packing and end-use become relevant only if no specific entry applies. Applying this interpretative rule and the coordinate decision relied on, the Tribunal held the goods remained under the specific tariff entries, the exemption under Notification No. 30/2004-CE was available, and the demand could not stand.

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Issues: Whether the goods manufactured by the assessee were classifiable under the specific tariff heading for absorbent cotton wool and cotton carded, or under Chapter 30 as wadding, gauze, bandages and similar articles put up for medical use, and whether the exemption under Notification No. 30/2004-CE was available.

Analysis: The goods were expressly covered by specific tariff sub-headings for absorbent cotton wool and cotton carded. The applicable interpretative rules require classification according to the terms of the headings and sub-headings, and only if no specific entry applies can broader considerations such as use, packing, or end-use be examined. Where a product squarely falls within a specific entry, it cannot be shifted to a more general or residuary entry merely because it is sold to hospitals or bears medical-pack markings. The same principle was applied in the earlier coordinate decision relied upon by the Tribunal.

Conclusion: The goods were correctly classifiable under the specific tariff entries and not under Chapter 30. The assessee was entitled to the exemption, and the demand was unsustainable.

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