Specific tariff classification prevails over residuary entry, and exemption extends to parts of compressors used in refrigerating equipment.

Electromagnetic clutches used as parts of compressors in refrigerating and air-conditioning equipment were treated as specific parts of such machinery and therefore fell under Tariff Item 29A(3), not the residuary Tariff Item 68. The residuary entry was unavailable because a specific tariff provision covered the goods. The exemption under Notification No. 80/62-C.E. was also available, as the notification exempted parts of refrigerating and air-conditioning appliances and machinery, and the exclusion of compressors did not clearly extend to parts of compressors merely because they formed components of the excluded principal article.

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Issues: (i) Whether electromagnetic clutches, being parts of compressors used in refrigerating and air-conditioning equipment, were classifiable under Tariff Item 29A(3) or under the residuary Tariff Item 68; (ii) whether such goods were entitled to exemption under Notification No. 80/62-C.E. dated 24-4-1962.

Issue (i): Whether electromagnetic clutches, being parts of compressors used in refrigerating and air-conditioning equipment, were classifiable under Tariff Item 29A(3) or under the residuary Tariff Item 68.

Analysis: Tariff Item 29A(3) covered parts of refrigerating and air-conditioning appliances and machinery. The goods were shown to be parts of compressors used in such equipment. A residuary entry can be applied only when no specific entry governs the goods. Since the goods were identifiable as specific parts of refrigerating and air-conditioning machinery, they could not be pushed into the residuary item.

Conclusion: The goods were classifiable under Tariff Item 29A(3) and not under Tariff Item 68, in favour of the assessee.

Issue (ii): Whether such goods were entitled to exemption under Notification No. 80/62-C.E. dated 24-4-1962.

Analysis: The notification exempted parts of refrigerating and air-conditioning appliances and machinery falling under Item 29A, while excluding compressors themselves. The goods were parts of compressors, not compressors as such. Excluding parts of excluded parts would defeat the operation of the exemption and make it ineffective. On a proper reading, the exclusion did not extend to the impugned goods.

Conclusion: The goods were eligible for exemption under Notification No. 80/62-C.E., in favour of the assessee.

Final Conclusion: The appeals succeeded, the classification under the residuary tariff entry was rejected, and the exemption claim was upheld.

Ratio Decidendi: Where goods are specifically classifiable under a dedicated tariff entry, they cannot be relegated to a residuary entry; and an exemption notification excluding a principal article does not, without clear words, exclude its parts merely because they are components of that article.

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