Residual exemption entry cannot cover audio amplifiers specifically covered by the primary tariff entry.

The notification's primary exemption entry covered cassette decks, amplifiers, equalisers, frequency synthesiser units, and combinations of those items designed for use in an audio system, while the residual entry applied only to goods not covered by that primary entry and falling under heading 8518.00. An audio amplifier by itself, and an audio reproduction system incorporating an amplifier, were treated as covered by the specific primary entry. Because the residual entry operated only where the goods were not already covered elsewhere, items capable of classification under the primary entry could not be shifted to the residual entry. The narrower reading urged for the primary entry was rejected, and the claimed exemption was denied.

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Issues: Whether theatre amplifier systems were classifiable under entry 2 of the Table to Notification 87/89 and therefore eligible for exemption, or whether they fell within entry 1 and were outside the claimed benefit.

Analysis: Entry 1 covered cassette deck, amplifier, equaliser, frequency synthesiser, or any combination of those items designed for use as or in an audio system, under the specified tariff headings. Entry 2 applied only to goods not covered by serial 1 falling under heading 8518.00. An audio amplifier by itself, or an audio reproduction system incorporating an amplifier, was held to fall within entry 1. Since entry 2 operated only residually, goods capable of falling under entry 1 could not be taken to entry 2. The contention that entry 1 applied only where an amplifier was combined with other items, or only when it formed part of an audio system, was rejected.

Conclusion: The goods were held to fall under entry 1, not entry 2, and the exemption claimed by the appellant was denied.

Final Conclusion: The appeal failed on tariff classification and exemption eligibility, leaving the departmental view intact.

Ratio Decidendi: A residuary exemption entry cannot be invoked for goods that are specifically covered by the primary exemption entry; an audio amplifier or an audio system incorporating an amplifier falls within the specific entry rather than the residual one.

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