HSN-based tariff classification prevails over residual entry for ball bearing parts where the tariff shows no contrary intention.

Parts of ball bearings, including needle rollers, cages, races, rings and bushes, were held classifiable under Heading 84.82 because the HSN explanatory notes specifically covered needle rollers, inner and outer races, and inner and outer rings. In tariff classification, the HSN nomenclature prevails unless the statute shows a contrary intention, and no contrary indication was found in the Central Excise Tariff Act, 1985. The residual Heading 84.85 therefore could not apply. The revenue's classification was upheld and the appeal failed.

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Issues: Whether the disputed parts and components of ball bearings, namely needle rollers, cages, races, rings and bushes, were classifiable under Heading 84.82 of the Central Excise Tariff Act, 1985 or under the residual Heading 84.85.

Analysis: The goods were admittedly parts of ball bearings. The relevant HSN explanatory notes to Heading 84.82 specifically covered needle rollers, inner and outer races, and inner and outer rings. In classification disputes, the nomenclature indicated by the HSN is to be followed unless the tariff contains a contrary intention. No contrary intention was found in the Central Excise Tariff Act, 1985.

Conclusion: The goods were correctly classifiable under Heading 84.82 and not under Heading 84.85.

Final Conclusion: The classification adopted by the revenue was upheld and the appeal failed.

Ratio Decidendi: Where goods are specifically covered by the HSN explanatory notes under a tariff heading, that classification prevails over a residual entry in the absence of a contrary indication in the tariff.

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