Specific classification of stylus-tip components prevails over raw material description for synthetic industrial diamonds.

Synthetic industrial diamonds specially shaped and identifiable for use in stylus tips were treated as parts of sound recorders or reproducers under Heading 92.01/13, not as industrial diamonds under Heading 71.02. The decisive factor was their specific form, intended use, and actual use in manufacturing stylii; no basic change in form, size, or character was shown, and the processing described was only for fitment. The more general description of the raw material did not override the specific classification based on character and use, and the earlier sapphire-tip classification was followed.

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Issues: Whether synthetic industrial diamonds imported for use in stylus tips were classifiable under Heading 92.01/13 as parts of sound recorders or reproducers, or under Heading 71.02 as industrial diamonds.

Analysis: The imported goods were found to have the special size and shape required for use in stylii and were in fact used in the manufacture of such stylii. No evidence was produced to show that the goods had lost their character as specially shaped components by any basic change in form, size, or character. The nature of the processing described was only for fitment, and the claimed alternative uses did not displace the specific classification of the goods by their identifiable character and intended use. The earlier decision treating sapphire tips as assessable under Heading 92.01/13 was followed.

Conclusion: The goods were correctly classifiable under Heading 92.01/13 and not under Heading 71.02; the departmental appeal succeeded.

Final Conclusion: The appellate order was set aside and the assessment treating the goods as parts of sound recorders or reproducers was restored.

Ratio Decidendi: Goods specially shaped and identifiable for use as parts of sound recorders or reproducers are classified according to that specific character and use, and not by a more general description of the raw material from which they are made.

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