Specific tariff entry for screws prevails over residuary classification where watch components answer the common meaning of screws.

Watch components described as barrel axle screw, bridge screw, dial key screw and lid screw were held classifiable as screws under Item 52 of the Central Excise Tariff Schedule, not under residuary Item 68. The classification turned on the specific tariff description and the common and trade understanding of the goods: they appeared as screws, were so described by manufacturers and in Indian Standards, and performed fastening functions in the watch assembly. Their use as parts of watches did not displace the specific entry, because end-use was not determinative where the tariff item covered the article by name. The order of the Collector (Appeals) was set aside and the Assistant Collector's classification restored.

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Issues: Whether the watch components described as barrel axle screw, bridge screw, dial key screw and lid screw were classifiable as screws under Item 52 of the Central Excise Tariff Schedule or under the residuary Item 68.

Analysis: Item 52 specifically covered screws, and goods falling within a specific tariff item could not be pushed into the residuary entry merely because they were also component parts of watches. The articles had the appearance of screws, were described as screws by the manufacturers and in the relevant Indian Standards specification, and performed the function of holding together parts of the watch assembly. The distinction sought to be drawn on minute gaps or on whether the head or shank performed the fastening function was treated as an undue refinement. Since the tariff entry did not refer to end-use, the fact that the goods were used in watches did not exclude them from Item 52.

Conclusion: The articles were classifiable as screws under Item 52 and not under Item 68.

Final Conclusion: The appeal succeeded, the order of the Collector (Appeals) was set aside, and the classification adopted by the Assistant Collector was restored.

Ratio Decidendi: Where a tariff entry specifically covers an article by name, it must be classified under that specific entry if it answers the common and trade understanding of that name, and it cannot be relegated to the residuary entry merely because of its end-use or because it forms part of a larger machine or instrument.

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