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Issues: Whether the prohibition in Rule 3 of the Transfer of Residence Rules extends beyond Rule 2 so as to deny the benefit of Rule 4 for import of personal computer and peripherals free of duty.
Analysis: Rule 3 was construed as containing a non obstante clause directed only against Rule 2. The wording "notwithstanding anything contained in Rule 2" was held to show that the restriction in Rule 3 displaces only the exemption under Rule 2 and not the entire set of Transfer of Residence Rules. Rule 4 was treated as a specific provision granting additional allowance for professional equipment, operating independently of the limitation in Rule 3. The interpretation adopted was supported by the principle that a specific provision prevails over a general one, and by the reasoning that an expansive reading of "these rules" would render the express reference to Rule 2 redundant.
Conclusion: The benefit of Rule 4 was held admissible, and the demand of duty on the computer and peripherals was set aside, subject to fulfilment of the other conditions for Rule 4 relief.