Specific tariff heading prevails over end-use classification for imported liquid crystal displays under customs rules.

Imported liquid crystal displays were classifiable under Heading 9013.80 because the Customs Tariff requires classification by the specific terms of the heading and the relevant Chapter Notes. Heading 9013 specifically covered LCDs, while Heading 9028 for electricity meters did not specifically cover them; intended end use in meters could not displace the applicable heading. Note 2(a) to Chapter 90 governed because the goods were articles covered in their own right, and Note 2(b) applied only to other parts and accessories not covered by Note 2(a). The residual interpretive rule could not be used before exhausting the heading and Chapter Note analysis.

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Issues: (i) whether imported liquid crystal displays were classifiable under Heading 9013.80 as liquid crystal devices or under Heading 9028.90 as parts of electricity meters; (ii) whether Note 2 to Chapter 90 and the General Rules for the Interpretation of the First Schedule required classification by the specific heading for the goods rather than by their end use.

Issue (i): whether imported liquid crystal displays were classifiable under Heading 9013.80 as liquid crystal devices or under Heading 9028.90 as parts of electricity meters.

Analysis: LCDs were specifically described in Heading 9013, and the only limitation was that they should not constitute articles more specifically provided elsewhere. The goods imported were LCDs and not articles falling under any more specific heading. Heading 9028 dealt with meters and their parts, but it did not specifically cover LCDs. Classification could not be shifted merely because the LCDs were intended for use in electricity meters.

Conclusion: The LCDs were classifiable under Heading 9013.80, not under Heading 9028.90, in favour of the assessee.

Issue (ii): whether Note 2 to Chapter 90 and the General Rules for the Interpretation of the First Schedule required classification by the specific heading for the goods rather than by their end use.

Analysis: Rule 1 gave primacy to the terms of the headings and the relevant Chapter Notes. Note 2(a) applied because the goods themselves were articles covered by Chapter 90 in their own right, so they had to be classified in their respective heading. Note 2(b) applied only to other parts and accessories not covered by Note 2(a). The residual rule in Rule 3 could not be invoked until the heading and Chapter Note analysis was exhausted.

Conclusion: Note 2(a) governed the classification and the specific heading for LCDs prevailed over end-use based classification.

Final Conclusion: The classification adopted by the authorities below was unsustainable, and the imported LCDs had to be assessed under Heading 9013.80.

Ratio Decidendi: For classification under the Customs Tariff, the terms of the heading and the relevant Chapter Notes control, and a product specifically covered by its own heading must be classified there even if it is intended for use as a part of another article.

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