Agricultural machinery classification excludes aquaculture equipment; paddle wheel aerators fall under the residual heading instead.

Paddle wheel aerators used exclusively in aquaculture were held not to fall within HSN 8436 for agricultural machinery because the tariff term "agriculture" was construed in its ordinary, confined sense and limited to the listed activities. Broader policy definitions of "farmer" and "agricultural produce" in another notification were found irrelevant to tariff classification. Aquaculture was treated as distinct from agriculture, and the specific-versus-residual principle was applied: since no specific entry covered the product, classification moved to HSN 8479 as a residual heading, attracting GST at the rate applicable to that entry.

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Issues: Whether Paddle Wheel Aerators used exclusively in aquaculture are classifiable under HSN 8436 as agricultural machinery or under HSN 8479 as a residual entry.

Analysis: The classification depended on the ordinary meaning of "agriculture" in the tariff entry and whether aquaculture equipment could be brought within the specific description of machinery for agriculture, horticulture, forestry, poultry-keeping or bee-keeping. The broader policy definition of "farmer" and the definition of "agricultural produce" in a different notification were found not to govern tariff classification under the relevant rate notification. The reasoning also treated the entry in HSN 8436 as confined to the listed activities, held aquaculture to be distinct from agriculture, and applied the principle that a specific entry must be preferred over a general or residual entry. As no specific tariff entry covered the product, it was placed in HSN 8479.

Conclusion: Paddle Wheel Aerators are not classifiable under HSN 8436 and are classifiable under HSN 8479; GST is attracted at the residual rate applicable to that heading, in favour of Revenue.

Ratio Decidendi: A tariff entry for agricultural machinery must be construed in its ordinary and confined sense, aquaculture is not agriculture for classification purposes, and where no specific entry applies the product falls under the residual heading.

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