Specific tariff entry prevails over general classification, and exemption cannot be extended beyond the notification's clear terms.

Sodium Hypochlorite solution was held to fall under Heading 2828 because a specific tariff entry prevails over a general heading, and the claim to classify it as a medicament under Chapter 30 was rejected. The exemption claim also failed because Notification No. 7/94 did not grant full exemption to Sodium Hypochlorite; it specifically provided for 20% basic excise duty, so the benefit available to Bleach Liquor could not be extended to the product. The classification and exemption analysis therefore supported Revenue's position.

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Issues: Whether Sodium Hypochlorite solution was classifiable under Heading 2828 as against Chapter 30, and whether the assessee was entitled to full exemption under Notification No. 7/94.

Analysis: The goods were found to be specifically covered by Heading 2828. For classification, a specific heading must prevail over a general heading. The claim to treat the product as a medicament under Chapter 30 was rejected. The assessee had also sought total exemption under Heading 2828, but the notification did not extend full exemption to Sodium Hypochlorite; instead, it contained a specific entry attracting 20% basic excise duty. The claim for exemption applicable to Bleach Liquor was therefore not available.

Conclusion: The product was correctly classifiable under Heading 2828 and the assessee was not entitled to full exemption.

Final Conclusion: The Commissioner (Appeals) order was set aside and the order in original was restored, resulting in success for the Revenue.

Ratio Decidendi: Where a product is specifically covered by a tariff entry, that specific entry governs classification, and an exemption cannot be extended beyond the clear terms of the notification.

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