Plain-language tariff classification leads anti-rust VPI paper to the residuary heading when the specific wax-coated entry does not fit.

Anti-rust VPI paper coated with wax on one side and an organic chemical on the other did not fall within sub-heading 4811.40 of the Central Excise Tariff Act, 1985 because that entry, read by its plain wording, covered paper coated, impregnated or covered with wax as described in the tariff. Interpretative rules could not displace the clear language of the specific entry. As the goods did not match the specific description, classification properly moved to the residuary sub-heading 4811.90.

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Issues: Whether anti-rust VPI paper coated with wax on one side and with an organic chemical on the other side is classifiable under sub-heading 4811.40 of the Central Excise Tariff Act, 1985 or under the residuary sub-heading 4811.90.

Analysis: The tariff description of sub-heading 4811.40 was construed on its plain terms. On that reading, paper coated only on one side with wax, while the other side is coated with a material not specified in that sub-heading, does not answer the description of paper coated, impregnated or covered with wax. The reliance placed on interpretative rules could not override the clear tariff language, and the residuary entry was available once the specific entry was found inapplicable.

Conclusion: The goods were not classifiable under sub-heading 4811.40 and were correctly classified under sub-heading 4811.90. The appeal was dismissed.

Ratio Decidendi: Where the tariff entry is unambiguous, classification must follow the plain wording of the entry, and a residuary heading applies when the goods do not fit the specific description.

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