Specific tariff classification prevails for tungsten filaments, defeating a broader lamp-entry levy

Imported tungsten filaments were classifiable under the specific tariff entry for tungsten and articles thereof, because that description directly matched the goods. They were not electric filament lamps, and their intended use as lamp components did not justify placing them under the broader lamp entry. The specific tariff description therefore prevailed over the general entry, and the higher levy based on the latter was unsustainable.

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Issues: Whether tungsten filaments imported for use in electric lamps were classifiable under Item 81.01/04(1) of the Indian Customs Tariff Act, 1975 or under Item 85.18/27(4) of that Act.

Analysis: The imported goods were tungsten filaments, and the description in Item 81.01/04(1) specifically covered tungsten and articles thereof. The filaments were not themselves electric filament lamps, and they could not function as lamps without further processing. Since the goods were specifically answerable to the more precise tariff description, they could not be brought under the broader lamp entry merely because they ultimately formed a component of an electric lamp. The classification had therefore to be governed by the specific entry rather than the general one.

Conclusion: The filaments were correctly classifiable under Item 81.01/04(1) and not under Item 85.18/27(4); the levy based on the higher entry was unsustainable.

Ratio Decidendi: Where imported goods are specifically described in one tariff entry, that specific classification prevails over a more general entry covering the finished article or its components.

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