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Issues: Whether magneto coils or contact sets imported as components of starting units of agro-industrial engines were classifiable under Heading 84.06 or under Heading 85.08 of the Customs Tariff.
Analysis: The imported goods were parts of the starting equipment of internal combustion engines manufactured as stationary industrial engines. Heading 85.08 specifically covered electrical starting and ignition equipment for internal combustion engines, including ignition magnetos, magneto dynamos, ignition coils, starter motors, sparking plugs and glow plugs. By contrast, the alternative heading under Chapter 84 was more general. Applying the interpretative principle that a specific description prevails over a general one, the goods fell within the more specific tariff entry. The claimed parity with the old tariff and the exemption notification did not displace the proper classification, save to the extent of any specific exemption.
Conclusion: The goods were correctly classifiable under Heading 85.08 and not under Heading 84.06; the classification adopted by the customs authorities was upheld.
Ratio Decidendi: Where imported goods are specifically covered by a tariff heading describing their function and character, that specific heading prevails over a broader residual or general heading in classification disputes.
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