Specific tariff heading prevails over residuary entry in classifying denatured salt as salt under excise law.

Denatured salt consisting principally of sodium chloride was treated as classifiable under Heading 25.01 of the Central Excise Tariff Act, 1985 because that heading expressly covers salt, including denatured salt, and the HSN notes support inclusion of sodium chloride remaining after chemical processing. Classification had to be determined by the wording of the heading and relative notes, with the specific heading prevailing over a residuary heading. Heading 38.23 could apply only if the goods were not otherwise specified or included, so the Revenue could not rely on it. The burden of justifying departure from the assessee's claimed classification lay on the Revenue, and that burden was not discharged.

---

---

Issues: Whether the product known as denatured salt was classifiable under Heading 25.01 of the Central Excise Tariff Act, 1985 or under the residuary Heading 38.23, and whether the Revenue had discharged the burden of proving classification under the residuary entry.

Analysis: The product was found by the departmental laboratory to consist principally of sodium chloride with other inorganic salts, and market enquiries showed that it was bought and sold as denatured salt and used as a substitute for common salt in industrial applications. Heading 25.01 expressly covers salt, including denatured salt, and the HSN explanatory notes also include residuary sodium chloride left after chemical processing. The interpretation rules require classification to be determined from the terms of the heading and relative notes, and the specific heading must prevail over a residuary heading. The Revenue's attempt to place the product under Heading 38.23 failed because that heading is residuary and can apply only where the goods are not elsewhere specified or included. The burden to justify departure from the assessee's claimed classification lay on the Revenue, and that burden was not discharged.

Conclusion: The product was correctly classifiable under Heading 25.01 and not under Heading 38.23, and the classification adopted by the assessee was upheld.

---