Specific tariff classification prevails for high-voltage insulators used in an electrical transmission system, excluding the residuary entry.

220 KV insulators and bushings were held to fall within the specific tariff entry for insulators designed for use in an electrical transmission system, rather than the residuary item. The tariff language was construed by its scope and not narrowly limited to transmission lines alone; a distribution sub-station was treated as part of the broader transmission and supply arrangement, and the high voltage nature of the goods supported that characterisation. Because the goods squarely matched the specific description, resort to the residuary entry was excluded, resulting in classification in favour of the assessee and against the Revenue.

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Issues: Whether 220 KV insulators/bushings imported by the respondents fell under the residuary tariff item or under the specific tariff item for insulators designed for use in an electrical transmission system of 400 volts or above.

Analysis: The competing tariff entries were examined on their language and scope. The specific entry covered insulators designed for use in an electrical transmission system and was not confined to transmission lines alone. A distribution sub-station forms part of the broader transmission and supply arrangement, and the distinction between transmission and distribution was not decisive. The high voltage of the goods also supported their character as items used in a transmission system. Since a specific entry applied, the residuary item had no role.

Conclusion: The goods were correctly classified under the specific tariff entry and not under the residuary entry, which was against the Revenue and in favour of the assessee.

Ratio Decidendi: Where goods squarely fall within a specific tariff description, classification under a residuary entry is excluded, and the expression covering an electrical transmission system is not to be narrowly confined by reference only to transmission lines.

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