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Issues: Whether treadle pumps, being feet-operated pumps used for lifting water for minor irrigation, were classifiable under Heading 8413.80 as pumps for liquids or under Heading 8424.10 as mechanical appliances of a kind used in agriculture or horticulture.
Analysis: The goods were found to be feet-operated pumps primarily designed for lifting water from depth. Heading 8413 covered pumps for liquids, including pumps other than power-driven pumps primarily designed for handling water or hand pumps. Heading 8424 covered mechanical appliances for projecting, dispersing or spraying liquids or powders, including appliances of a kind used in agriculture or horticulture. The goods were not appliances for projecting, dispersing or spraying liquids or powders, but were pumps for handling water. Applying the rule that the more specific description prevails over a general description, the classification under Heading 8413.80 was held to be appropriate.
Conclusion: The treadle pumps were correctly classifiable under Heading 8413.80 and not under Heading 8424.10.
Final Conclusion: The appeal failed and the classification adopted by the department was sustained.
Ratio Decidendi: Where goods answer the specific description of pumps for liquids, they cannot be shifted to a more general heading for agricultural appliances merely because their end use is agricultural.