Specific tariff heading for liquid crystal devices prevails over general parts heading in LCD module classification dispute.

Imported LCD modules comprising the panel, driver circuit, backlight unit, PCB and inverter in a metal casing were classified as liquid crystal devices under Heading 90138010. The specific tariff description for liquid crystal devices prevailed over the broader parts heading in Heading 8529, which applies only to goods suitable for use solely or principally with apparatus of Heading 8525 to 8528. Section Note 2 of Section XVI did not govern Chapter 90, and Note 1(m) excluded Chapter 90 articles from Section XVI. The Revenue's classification was set aside, and the goods were held to fall under Heading 90138010.

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Issues: Whether liquid crystal devices imported as LCD modules were classifiable under Heading 9013 80 10 or under Heading 8529 90 90.

Analysis: The imported goods were not mere liquid crystal panels but assemblies comprising the panel, driver, circuit, backlight unit, PCB and inverter in a metal casing, and were therefore liquid crystal devices. Heading 9013 specifically names liquid crystal devices and sub-heading 90138010 is exclusively carved out for LCDs. By contrast, Heading 8529 is a general parts heading for goods suitable for use solely or principally with apparatus of Heading 8525 to 8528. Since the goods were specifically covered by name in Heading 9013, the more specific description prevailed over the general parts description in Heading 8529. Section Note 2 of Section XVI did not govern Chapter 90, and Note 1(m) excluded Chapter 90 articles from Section XVI. The Supreme Court ruling on LCDs used in energy meters supported classification under Heading 9013, and foreign customs classifications had no binding force.

Conclusion: The imported goods were classifiable under Heading 90138010 and not under Heading 8529 90 90.

Final Conclusion: The appeals succeeded and the classification adopted by the Revenue was set aside in favour of classification as liquid crystal devices under Heading 90138010.

Ratio Decidendi: Where goods are specifically described by name in a tariff heading, that specific description prevails over a broader parts heading, and excluded section notes cannot be used to displace the specific classification within Chapter 90.

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