Specific tariff entry prevails over general classification; car air-conditioning kit stayed covered, with only the compressor excluded.

A specific exemption entry for parts and accessories of car air-conditioners, including car air-conditioning kits, prevails over a general entry for air-conditioners. The later explanation was read narrowly: it excluded only the automotive gas compressor, with or without magnetic clutch, and not the entire car air-conditioning kit. On that construction, the kit remained within the specific entry, while the compressor was separately liable to duty. The governing principle is that a specific classification entry overrides a general one, and an explanatory exclusion cannot be expanded beyond its clear language.

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Issues: Whether car air-conditioning kits were classifiable under the entry for air-conditioners or under the specific entry introduced for parts and accessories of car air-conditioners including car air-conditioning kits, and whether the later explanation excluded only the compressor or the entire kit from that specific entry.

Analysis: The notification initially contained a general entry for air-conditioners and, after amendment, introduced a specific entry for parts and accessories of car air-conditioner including car air-conditioning kit. The specific entry was intended to cover car air-conditioning kits as such, and by settled principles of classification a specific entry overrides a general one. The later explanation was construed as excluding only the automotive gas compressor, with or without magnetic clutch, from the kit and not as removing the entire car air-conditioning kit from the specific entry. On that reading, the remaining kit continued to fall within the specific entry, while the excluded compressor was separately liable to duty.

Conclusion: The car air-conditioning kit, minus the automotive gas compressor with or without magnetic clutch, was classifiable under the specific entry for parts and accessories of car air-conditioner including car air-conditioning kit; the appeal succeeded for the assessee.

Ratio Decidendi: Where an exemption notification contains both a general entry and a later specific entry for a commodity, the specific entry governs; an explanatory exclusion must be read narrowly and cannot be construed to exclude the entire commodity unless the language clearly so provides.

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