Specific tariff heading for liquid crystal devices prevailed over general monitor parts classification for imported LCD panels.

Imported LCD panels were treated as classifiable under CTH 9013 8010 as liquid crystal devices, because the tariff entry specifically naming such devices was more specific than the general entry for parts suitable for use with monitors under CTH 8529 9090. The analysis relied on the HSN description, the wording of CTH 9013, and the principle that goods described by a specific heading should be classified there unless a more specific provision applies. Section Note 2 of Section XVI did not displace the specific coverage of Chapter 90, so the Revenue's proposed classification was rejected and the claimed BCD exemption followed accordingly.

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Issues: (i) Whether imported LCD panels were classifiable under CTH 9013 8010 as liquid crystal devices or under CTH 8529 9090 as parts suitable for use with monitors, and whether the appellant was entitled to the BCD exemption claimed.

Analysis: The tariff entry specifically naming liquid crystal devices was held to be more specific than the general entry covering parts suitable for use principally with the relevant apparatus. The reasoning relied on the HSN description, the express wording of CTH 9013, and the earlier judicial view that goods which are themselves described by a specific heading must be classified there unless more specifically covered elsewhere. The reliance on Section Note 2 of Section XVI did not assist the Revenue because the note did not displace the specific coverage of Chapter 90. The classification accepted by the Revenue was therefore found unsustainable.

Conclusion: The LCD panels were held to be classifiable under CTH 9013 8010, and not under CTH 8529 9090, with the result that the appellant succeeded on the classification issue and the claimed exemption followed accordingly.

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