Specific tariff entry for saw blade bodies prevails over general machine-tool parts classification for stone-cutting imports.

Imported steel strips used for stone cutting were treated as blade bodies for attachment to diamond segments and, on that description, as components of a saw arrangement rather than general machine-tool parts. Tariff Heading 82.01/04, covering blades for hand or machine saws including toothless saw blades, was held to be the specific entry applicable. Tariff Heading 84.45/48, being a broader provision for machine tools and their accessories or parts, did not apply where the goods were shown to be saw components. The specific tariff entry prevailed over the general one, so the classification under Heading 82.01/04 was upheld and the Collector's view was set aside.

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Issues: Classification of imported steel strips for stone cutting under Tariff Heading 82.01/04 or Tariff Heading 84.45/48.

Analysis: Tariff Heading 82.01/04 covers blades for hand or machine saws, including toothless saw blades, whereas Tariff Heading 84.45/48 covers machine tools and accessories or parts suitable for use solely or principally with such machine tools. On the description available, the goods were blade bodies meant for attachment to diamond segments and were therefore part of a saw arrangement rather than general parts of machine tools. Where a specific tariff entry covers the goods, that entry prevails over a more general one.

Conclusion: The goods were classifiable under Tariff Heading 82.01/04 and not under Tariff Heading 84.45/48. The classification adopted by the Collector was set aside and the appeal succeeded in favour of the Revenue.

Ratio Decidendi: For tariff classification, a specific entry for saw blades or blade bodies prevails over a general entry for parts of machine tools when the description shows the goods are meant for use as saw components.

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