Specific tariff entry prevails for axle studs; end-use does not alter classification, and exemption remains conditionally available.

Axle studs described as headless bolts threaded at both ends were held to fall within Tariff Item 52, because that entry specifically covered bolts, nuts and screws and its Explanation included screw studs. Their intended use in motor vehicles and special specifications did not change classification, since Item 52 did not turn on end-use and was more specific than the general motor vehicle parts entry under Item 34-A. The exemption under Notification No. 158/71-CE remained available if its conditions were satisfied. The classification under the specific tariff entry was sustained, while the exemption benefit was preserved subject to compliance with the notification.

---

---

Issues: (i) Whether the axle studs manufactured by the appellants were classifiable under Tariff Item 52 as bolts, nuts and screw studs, or under Tariff Item 34-A as parts and accessories of motor vehicles; (ii) Whether the appellants were entitled to the benefit of Notification No. 158/71-CE if the goods were classifiable under Tariff Item 52.

Issue (i): Whether the axle studs manufactured by the appellants were classifiable under Tariff Item 52 as bolts, nuts and screw studs, or under Tariff Item 34-A as parts and accessories of motor vehicles.

Analysis: The goods were described as axle studs and the samples showed a headless bolt threaded at both ends. Tariff Item 52 specifically covered bolts, nuts and screws, and its Explanation expressly included screw studs. The Tribunal held that the product answered that description. The fact that the articles were made for use in motor vehicles and had special specifications did not alter the classification because the tariff entry contained no reference to end-use. Item 34-A was a general residuary description for motor vehicle parts not otherwise specified, whereas Item 52 was the more specific entry.

Conclusion: The goods were classifiable under Tariff Item 52 and not under Tariff Item 34-A.

Issue (ii): Whether the appellants were entitled to the benefit of Notification No. 158/71-CE if the goods were classifiable under Tariff Item 52.

Analysis: Having upheld classification under Tariff Item 52, the Tribunal directed that the exemption notification would apply if the conditions attached to it were satisfied. The relief was thus linked to compliance with the notification.

Conclusion: The appellants were entitled to the benefit of Notification No. 158/71-CE subject to fulfilment of its conditions.

Final Conclusion: The classification adopted by the lower authorities was sustained, but the exemption notification benefit was kept available to the appellants upon satisfaction of the prescribed conditions.

Ratio Decidendi: Where a tariff entry specifically covers the goods by name or inclusive explanation, that specific entry prevails over a more general description, and end-use is immaterial if the tariff item does not refer to use or adaptation.

---