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Issues: Whether peeling rollers obtained after peeling of log wood of thickness exceeding 6 mm are classifiable under Tariff Heading 44.03 as peeled wood or under Tariff Heading 44.05 as wood continuously shaped along edges or faces.
Analysis: The Tribunal followed its earlier decision on an identical dispute and held that peeling rollers, though resulting from the peeling process, answer the description of peeled wood more specifically than Heading 44.05. The competing tariff entries were considered under the interpretative rule that where goods are classifiable under more than one heading, the more specific description prevails. On that reasoning, the product was treated as falling under Heading 44.03, and the consequential exemption attached to that heading was held applicable.
Conclusion: The goods were held classifiable under Heading 44.03 and not under Heading 44.05, in favour of the assessee.
Final Conclusion: The Revenue's challenge to the classification failed, and the lower appellate classification in favour of the assessee stood affirmed.
Ratio Decidendi: For tariff classification, the entry giving the more specific description of the goods prevails over a broader competing entry, and goods answering the description of peeled wood are classifiable under Heading 44.03 rather than Heading 44.05.