Specific classification prevails over residual entry for gas-filled bulbs, preserving exemption treatment.

Specific tariff or exemption descriptions must be applied before any residual or general classification. Gas-filled bulbs of 10W falling within the prescribed voltage limit matched the specific exemption entry for gas-filled bulbs, so they could not be moved to the broader residual category of electric filament or discharge lamps merely because they also fit that description. The classification principle therefore favoured the specific entry, and the exemption treatment for the importer was upheld.

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Issues: Whether gas-filled bulbs of 10W and not exceeding 60V were eligible for exemption under the specific entry for gas-filled bulbs, or were to be classified residually as electric filament or discharge lamps for the purpose of countervailing duty.

Analysis: The Notification classified electric filament or discharge lamps under a broad description, but also contained a specific entry for gas-filled bulbs not exceeding 60W. The specific entry had to be exhausted first, and the broader residual entry could apply only where the goods did not fall within any more specific description. Since the imported goods were gas-filled bulbs of 10W and within the prescribed voltage limit, they answered the specific description and could not be shifted to the residual entry merely because they were also electric filament or discharge lamps.

Conclusion: The goods were correctly classifiable under the specific exemption entry for gas-filled bulbs, and not under the residual entry for electric filament or discharge lamps.

Final Conclusion: The Revenue's challenge to the classification failed, and the exemption treatment in favour of the importer was upheld.

Ratio Decidendi: Where goods satisfy a specific tariff or exemption description, they must be classified under that specific entry before any residual or general entry can be applied.

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