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Issues: Whether plastic watch straps were classifiable under Chapter Heading 39.22 as articles of plastic and eligible for exemption under Notification No. 132/86, or under Chapter Heading 91.13 as watch straps, watch bands and watch bracelets and parts thereof.
Analysis: The classification had to be determined with reference to the Central Excise Tariff Act, 1985 and the Rules for the Interpretation of the Schedule. Rule 3(a) gives preference to the heading providing the most specific description over a more general description. Watch straps were specifically covered by Chapter Heading 91.13, which directly described the goods. In such circumstances, the fact that the straps were made of plastic did not justify placing them under the more general plastic-heading 39.22. The exemption claim based on Notification No. 132/86 therefore could not succeed.
Conclusion: The plastic watch straps were correctly classifiable under Chapter Heading 91.13 and not under Chapter Heading 39.22. The appeal failed and was rejected, in favour of the Revenue.