Tariff classification turns on essential character: canned fruits and fruit squashes fall under the more specific headings, not residual entries.

For tariff classification, goods must be placed under the heading that best fits their essential character and the tariff wording, and explanatory notes cannot override the statutory heading or chapter notes. Canned fruits in syrup were treated as fruit in substance, merely cleaned, packed and sealed for preservation, so they fell under Heading 08.01 rather than Heading 20.01. Fruit squashes and cordials were treated as preparations of fruit juice, not as beverages or residual products, so they fell under Heading 20.01 rather than Heading 21.07. The commentary emphasises that a residual heading yields to a more specific entry.

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Issues: (i) Whether canned fruits in syrup were classifiable under Heading 08.01 or under Heading 20.01 of the Central Excise Tariff. (ii) Whether fruit squashes and cordials were classifiable under Heading 20.01 or under Heading 21.07 of the Central Excise Tariff.

Issue (i): Whether canned fruits in syrup were classifiable under Heading 08.01 or under Heading 20.01 of the Central Excise Tariff.

Analysis: The canned fruits remained fruit in substance, only made more presentable and long-lasting by cleaning, packing and sealing. Heading 20.01 covers preparations of vegetables, fruit, nuts or other parts of plants, whereas the goods were not preparations in the nature of jams, jellies, marmalades, juices or similar products. Note 1 to Chapter 20 did not carry the goods into that Chapter, because they were not shown to be preparations of fruit within that Chapter. The explanatory notes to Chapter 8 supported inclusion of fruits intended for human consumption even after processing and in airtight containers, and could not override the tariff language and statutory notes.

Conclusion: Canned fruits in syrup were classifiable under Heading 08.01 and sub-heading 0801.10, in favour of the assessee.

Issue (ii): Whether fruit squashes and cordials were classifiable under Heading 20.01 or under Heading 21.07 of the Central Excise Tariff.

Analysis: Heading 20.01 expressly covered preparations of fruit juices, while Note 5(j) to Chapter 21 covered preparations for beverages and not beverages themselves. Squashes and cordials were treated as fruit products or preparations of fruit juice, not as the fruit juice itself, and the residual Heading 21.07 could not displace the more specific Heading 20.01. The definitions in the Fruit Products Order, 1955 and the Prevention of Food Adulteration Rules, 1955 showed that squashes and cordials were distinct from plain fruit juice and were preparations thereof.

Conclusion: Fruit squashes and cordials were classifiable under Heading 20.01 and sub-heading 2001.10, in favour of the assessee.

Final Conclusion: The classification adopted by the lower authorities was set aside, and both sets of goods were held to fall under the tariff entries pressed by the appellants.

Ratio Decidendi: For tariff classification, goods must be placed under the most appropriate specific entry according to their essential character and tariff wording; explanatory notes cannot override the statutory heading and chapter notes, and a residual heading yields to a more specific one.

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