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Issues: Whether vulcanised fibre sheets were classifiable under Heading 39.13, sub-heading 3913.30, of the Schedule to the Central Excise Tariff Act, 1985, or under Heading 39.20, sub-heading 3920.31, as a product of other plastics.
Analysis: Vulcanised fibre was shown to be manufactured in the form of sheets, rolls, rods and tubes, and the evidence indicated that these were its primary manufactured forms. Chapter Note 6 to Chapter 39 defines primary forms in a restricted way, referring to forms in the mass such as blocks of irregular shape, lumps, powders, granules, flakes and similar bulk forms. Sheets, though a primary manufactured form of vulcanised fibre, are not similar to the forms specified in the note. If Heading 39.13 were denied application to sheets, the specific entry for vulcanised fibre would be deprived of effect. A construction that renders a statutory entry nugatory is to be avoided, and a specific entry must prevail over a general entry where the article squarely answers the specific description.
Conclusion: Vulcanised fibre sheets are classifiable under Heading 39.13, sub-heading 3913.30, and not under Heading 39.20.
Ratio Decidendi: Where a tariff item specifically names the commodity, the classification must be given effect so as not to render the entry redundant, and a general residuary description cannot displace the specific entry when the goods answer the specific description.