Specific tariff classification governs railway springs of iron and steel, attracting GST under the dedicated heading.

Springs of iron and steel supplied for use in railways are classified under HSN 7320, because they are treated as parts of general use under Note 2(b) to Section XV, while Note 2 to Section XVII excludes such items from railway parts and accessories. HSN 8607 is a general railway-parts entry, but HSN 7320 specifically covers springs of iron and steel, including railway springs. Applying the specific-over-general principle under Rule 3(a) of the General Rules for Interpretation, the specific heading prevails. The goods are therefore taxable at 18% under Serial No. 234 of Schedule III of Notification No. 1/2017-Central Tax (Rate).

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Issues: Whether springs of iron and steel supplied for use in railways are classifiable under HSN 7320 or under HSN 8607, and the consequent GST rate applicable.

Analysis: Springs of iron and steel are treated as parts of general use under Note 2(b) to Section XV of the First Schedule to the Customs Tariff Act, 1975. By contrast, Note 2 to Section XVII excludes such parts of general use from the scope of parts and accessories of railway goods. HSN 8607 is a general entry for railway parts, whereas HSN 7320 specifically covers springs of iron and steel, including springs for railways. Applying the specific-over-general principle embodied in Rule 3(a) of the General Rules for the Interpretation of the First Schedule to the Customs Tariff Act, 1975, the specific tariff heading must prevail.

Conclusion: Springs of iron and steel for railways are classifiable under HSN 7320 and taxable at 18% under Serial No. 234 of Schedule III of Notification No. 1/2017-Central Tax (Rate) dated 28.06.2017.

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