Specific tariff entry prevails over residuary heading in classification; product fell under Chapter 20, not Chapter 21.

Chapter 20 specifically covered preparations of vegetables, fruit, nuts or other parts of plants, and its Note 1 confined the chapter to products prepared or preserved by specified processes. Chapter 21 was only a residual heading for edible preparations not elsewhere specified or included. Applying Rule 3(a) of the Interpretation Rules, the more specific tariff entry prevailed over the general residuary entry. The product was therefore classifiable under Chapter Heading 20.01 and sub-heading 2001.90, not under Chapter 21, and the assessee succeeded; the duty demand based on Chapter 21 classification did not survive.

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Issues: Whether the product was classifiable under Chapter Heading 20.01 / sub-heading 2001.90 as preparations of vegetables, fruit, nuts or other parts of plants, or under Chapter 21 as an edible preparation not elsewhere specified or included.

Analysis: Chapter 20 specifically covered preparations of vegetables, fruit, nuts or other parts of plants, and Chapter Note 1 confined that chapter to products prepared or preserved by specified processes. The competing entry in Chapter 21 was a general residual heading for edible preparations not elsewhere specified or included. Applying Rule 3(a) of the Rules for the Interpretation of the Schedule, the more specific entry was held to prevail over the general heading. On that basis, the product was found to answer the description in Chapter 20 rather than Chapter 21.

Conclusion: The product was classifiable under Chapter Heading 20.01 and sub-heading 2001.90, not under Chapter 21; the assessee succeeded.

Final Conclusion: The classification dispute was decided in favour of the assessee and the duty demands based on Chapter 21 classification did not survive.

Ratio Decidendi: Where a tariff item specifically covers the goods, that specific entry prevails over a general residual entry for classification purposes.

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