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Issues: Whether the imported mounts and heads for toilet sprays were classifiable as parts of scent sprays under Heading 96.16 or as parts of mechanical appliances under Heading 84.24.
Analysis: The article imported was only the mount and head used with a reservoir for liquid soap. The relevant tariff notes showed that Heading 84.24 covered hand-controlled appliances operating with high-pressure air or steam sources, whereas Heading 96.16 specifically covered toilet sprays, including mounts and head pieces for toilet sprays. The use of the goods for dispensing and spraying liquid soap brought them within the specific coverage of Heading 96.16, and they could not be classified under Heading 84.24.
Conclusion: The goods were correctly classified under Heading 96.16 and not under Heading 84.24, in favour of Revenue.
Final Conclusion: The Revenue's challenge succeeded and the classification adopted by the original authority was restored and affirmed.
Ratio Decidendi: Where a tariff heading specifically covers mounts and head pieces for toilet sprays, such goods are to be classified under that specific heading rather than under the general heading for mechanical appliances used for projecting, dispersing or spraying liquids.
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