Specific tariff classification for TFT-LCD panels prevailed over general parts heading, confirming Chapter 90 treatment for liquid crystal devices.

Imported TFT-LCD panels were found classifiable under Chapter Heading 9013.8010 as liquid crystal devices, because the specific Chapter 90 entry prevailed over the general parts heading in Chapter 85. Applying Section XVI Note 2(a), the tribunal held that goods described more specifically in another heading cannot be shifted to Chapter XVI merely because they are used as parts of television apparatus. The panels were commercially known and sold as LCD panels, and the revenue's reliance on Chapter Heading 8529.9090 did not displace the more specific tariff classification. The cited authorities were distinguished as involving different section notes and did not alter the result.

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Issues: Whether imported TFT-LCD panels were classifiable under Chapter Heading 9013.8010 as liquid crystal devices, or under Chapter Heading 8529.9090 as parts suitable for use solely or principally with apparatus of Chapter 85.

Analysis: The dispute turned on whether the goods were covered more specifically by Chapter Heading 9013, which applies to liquid crystal devices not constituting articles provided for more specifically elsewhere, or by Chapter Heading 8529, which covers parts suitable for use solely or principally with apparatus of headings 8525 to 8528. The relevant Section XVI notes were applied, particularly the rule that articles specifically covered by Chapter 90 cannot be displaced into Chapter XVI merely because they are used as parts of television sets. Chapter Note 2(a) to Section XVI gives priority to goods described in another heading, and the tribunal found that the LCD panels were commercially known and sold as LCD panels and were not described more specifically by the parts heading relied on by the revenue. The reasoning also distinguished the cited authorities dealing with different section notes and held that those principles did not override the specific tariff entry covering liquid crystal devices.

Conclusion: The goods were held classifiable under Chapter Heading 9013.8010 and not under Chapter Heading 8529.9090, in favour of the assessee.

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