Specific tariff heading prevails over general parts entry for tension pulleys; end use and provisional approval cannot override classification.

Tension pulleys manufactured for textile machinery were held classifiable under Heading 84.83 rather than the general parts entry in Heading 84.48, because pulleys are specifically covered by Heading 84.83 and Section XVI Note 2(a) requires goods named in a tariff heading to be classified there. The reference to parts suitable for textile machinery could not override the specific heading, and end use did not displace the tariff language. The earlier provisional classification did not bar reclassification, as there is no estoppel in taxation. The differential duty demand was therefore validly confirmed.

---

---

Issues: Classification of tension pulleys manufactured for textile machinery under Heading 84.48 or Heading 84.83 of the Central Excise Tariff, and whether the differential duty demand could be sustained despite the earlier provisional approval of classification.

Analysis: The products were tension pulleys, and pulleys were specifically covered under Heading 84.83. Under Note 2(a) of Section XVI, goods that are themselves included in a heading of Chapters 84 or 85 must be classified in that heading, and Note 2(b) applies only to other parts that cannot be so classified. The reference in Heading 84.48 to parts and accessories suitable for use solely or principally with textile machinery could not override the specific coverage of pulleys under Heading 84.83. The Tribunal also noted that end use cannot displace a specific tariff entry and that there is no estoppel in taxation, so the earlier provisional classification did not prevent reclassification on a fresh list and consequential confirmation of duty.

Conclusion: The tension pulleys were correctly classified under Heading 84.83, not Heading 84.48, and the demand for differential duty was validly confirmed.

Final Conclusion: The appeal failed on the classification question and the associated duty demand, and the order under challenge was upheld.

Ratio Decidendi: Where goods are specifically covered by a tariff heading, they must be classified in that heading and cannot be shifted to a general parts entry on the basis of end use or prior provisional approval.

---