Specific tariff entry prevails over residuary heading for stringing equipment used in lifting, pulling and tensioning operations.

Imported hydraulic tensioners, pullers, hydrostatic driver pullers and oleodynamic winch pullers used in stringing operations were classifiable as lifting and handling machinery under Heading 84.22 because they lifted conductor drums and performed pulling and tensioning functions integral to that operation. As Heading 84.22 specifically covered winches and related handling equipment, the residuary Heading 84.59(1) could not apply. The principle applied was that a specific tariff entry prevails over a residuary entry, and the assessee's classification under Heading 84.22 was upheld.

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Issues: Whether hydraulic tensioner, hydraulic puller, hydrostatic driver puller and oleodynamic type winch puller imported for stringing operations were classifiable under Heading 84.22 as lifting, handling, loading or unloading machinery, or under the residuary Heading 84.59(1).

Analysis: The items were used to lift conductor drums to the top of transmission towers for stringing and performed the functions of pulling and tensioning cable during that operation. Heading 84.22 specifically covered lifting and handling machinery, including winches and related equipment, whereas Heading 84.59(1) was a residuary entry for machines not falling under any other heading. A specific entry prevails over a residuary entry, and the disputed goods answered the description of handling machinery.

Conclusion: The disputed items were correctly classifiable under Heading 84.22 and not under Heading 84.59(1), and the assessee's classification was upheld.

Final Conclusion: The appeals failed, and the reassessment under Heading 84.22 stood confirmed.

Ratio Decidendi: Where imported equipment answers the description of a specific tariff entry for lifting or handling machinery, it cannot be classified under a residuary heading meant for machines not elsewhere specified.

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