Specific tariff classification prevails for absorbent cotton wool, defeating the duty demand and consequential interest and penalty.

Absorbent cotton wool, when not medicated, was held classifiable under Chapter Heading 5601 2110 as the more specific and later tariff entry, rather than Chapter Heading 3005 9090. Prior Tribunal decisions on identical goods were followed, and no basis was found to depart from that settled classification view. Once the assessee's classification was accepted, the duty demand could not survive, and the consequential levy of interest and penalty also fell. The demand of duty, interest and penalty was therefore set aside.

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Issues: Whether absorbent cotton wool, not medicated, was correctly classifiable under Chapter Heading 5601 2110 as claimed by the assessee or under Chapter Heading 3005 9090 as claimed by the department, and whether the demand of duty, interest and penalty could survive.

Analysis: The competing tariff entries were examined in the light of prior Tribunal decisions on identical goods. The product was held to answer the more specific tariff entry under Chapter Heading 5601 2110, which was also treated as the later entry in the tariff scheme. The earlier coordinate bench decisions were followed, and no reason was found to depart from that settled view. Once the classification claimed by the assessee was accepted, the duty demand could not stand, and the consequential levy of interest and penalty also failed.

Conclusion: Absorbent cotton wool was held classifiable under Chapter Heading 5601 2110, and the demand of duty, interest and penalty was set aside in favour of the assessee.

Ratio Decidendi: Where goods answer a more specific and later tariff entry, that classification prevails over a more general competing entry, and any demand founded on the rejected classification cannot survive, along with its consequential interest and penalty.

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