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Issues: Whether float wash, water shower and water filter were prima facie classifiable under headings 84.21 and 84.24 of the Central Excise Tariff rather than as parts of paper making machinery under heading 8439.90, and whether pre-deposit of duty and penalty should be dispensed with.
Analysis: The goods performed distinct functions and were specifically covered by headings 84.21 and 84.24. The reasoning that they became parts of paper making machinery merely because they were used in paper manufacturing units was not accepted at the prima facie stage. The principle that a specific entry prevails over a general one supported classification under the specific headings. The reliance on Section Note 3 of Section XVI was not found persuasive for the purpose of insisting on pre-deposit.
Conclusion: The appellants made out a prima facie case for classification under headings 84.21 and 84.24, and unconditional stay of the pre-condition of deposit was granted.