Specific tariff classification prevails over residual headings, defeating exemption linked to a different classification.

Goods specifically covered by Heading 85.31, which covers electric sound or visual signalling apparatus including indicator panels, could not be reclassified under residual Heading 84.79 or Heading 84.71. Chapter Note 5(b) to Chapter 84 directs that appliances working with or in conjunction with a computer be classified by their respective functions, and only fall in a residual heading where no specific heading applies. Because a specific tariff entry existed, resort to the residual heading was impermissible, and exemption linked to the alternative classification under Notification No. 76/86-C.E. was correctly denied.

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Issues: Whether the goods in question were correctly classifiable under Heading 85.31, or could be placed under Heading 84.79 or Heading 84.71 so as to qualify for exemption under Notification No. 76/86-C.E.

Analysis: Heading 85.31 specifically covers electric sound or visual signalling apparatus, including indicator panels. Heading 84.79 is a residual heading for machines and mechanical appliances having individual functions not specified elsewhere. Note 5(b) to Chapter 84 excludes appliances working with or in conjunction with a computer from Heading 84.71 and directs classification according to their respective functions, or in residual headings only if no specific heading applies. Since the goods had a specific coverage under Heading 85.31, they could not be shifted to the residual Heading 84.79 merely because they were not classifiable under Heading 84.71.

Conclusion: The goods were classifiable under Heading 85.31 and not under Heading 84.79 or Heading 84.71. The denial of exemption based on the correct classification was justified, and the Revenue succeeded.

Ratio Decidendi: Where goods are specifically covered by a tariff heading, classification under a residual heading is impermissible, and exemption linked to a different heading cannot be claimed.

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