Specific tariff entry prevails over general rubber-products entry for automobile fan belts used in two-wheelers and tractors.

Automobile fan belts used for two-wheelers and tractors were classified under the specific schedule entries for vehicle parts and accessories, not under the general entry for rubber products. The court applied the settled principle that a specific entry prevails over a general or residual entry where the goods are squarely covered by the specific description. The revisionary assessment was also found unsustainable on the facts, including the selective exercise of suo motu revision for only some assessment years. The impugned revision order and higher tax assessment were set aside, and the dealer succeeded.

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Issues: Whether automobile fan belts manufactured and sold for two-wheelers and tractors were classifiable under the specific entries for vehicle parts and accessories or under the general entry for rubber products, and whether the suo motu revision under the sales tax statute was sustainable.

Analysis: The invoices showed that the goods were fan belts used as accessories for two-wheelers and tractors. Those goods were specifically covered by the entries relating to two-wheeler parts and tractor parts in the First Schedule, while the relied upon entry for rubber products was a general entry dealing with conveyor, transmission or elevator belts. Where a specific entry squarely applies, the goods cannot be shifted to a general entry. The selective exercise of suo motu revision for only some assessment years also did not support the revenue's classification.

Conclusion: The goods were held to fall under the specific entries for two-wheeler and tractor parts and accessories, not under the general rubber-products entry, and the assessee succeeded.

Final Conclusion: The impugned revisionary order and the resulting higher tax assessment were set aside, and the tax case was allowed in favour of the dealer.

Ratio Decidendi: When goods are specifically covered by a tariff or schedule entry, they must be classified under that specific entry and cannot be assessed under a more general residual entry.

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