Specific tariff entry prevails for radio cassette recorders over broader audio-component classification under the notification.

A radio cassette recorder was held classifiable under the specific entry for reception apparatus for radio broadcasting combined with sound recording or reproducing apparatus, rather than the broader entry for cassette decks and related audio components. The notification distinguished between a general audio-system entry and a more specific description covering radio reception apparatus, including goods combined in the same housing with recording or reproducing functions. Because the product matched the specific description, the specific entry prevailed over the overlapping general entry for classification purposes.

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Issues: Whether a radio cassette recorder is classifiable under Sl. No. 1 or Sl. No. 14 of Notification No. 87/89 dated 1-3-1989.

Analysis: Sl. No. 1 covered cassette deck, amplifier, equaliser, frequency synthesiser or combinations thereof designed for use as or in an audio system, while Sl. No. 14 specifically covered reception apparatus for radio broadcasting, whether or not combined in the same housing with sound recording or reproducing apparatus, other than those covered by Sl. No. 1. The product was a radio cassette recorder, i.e. a reception apparatus for radio broadcasting combined with sound recording and reproducing apparatus, and therefore fell within the specific description at Sl. No. 14. Since the notification expressly covered the product by a specific entry, the broader contention under Sl. No. 1 could not prevail.

Conclusion: The radio cassette recorder is covered by Sl. No. 14 of Notification No. 87/89 dated 1-3-1989 and not by Sl. No. 1; the Revenue's appeal fails.

Ratio Decidendi: Where a tariff notification contains a specific entry covering the goods by description, that specific entry governs classification over a more general or otherwise overlapping entry.

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