Specific tariff classification governs liquid crystal displays used in meters, displacing the parts-and-accessories heading.

Liquid crystal displays imported for use in electricity meters remain classifiable under Heading 9013 as liquid crystal devices, because a specific tariff entry prevails over the parts-and-accessories rule in Heading 9028. The applicability of Chapter Note 2 to Chapter 90 does not displace a specific classification when the goods are expressly covered elsewhere in the tariff. The exemption claim under Notification No. 24/2005-Cus could not be denied merely on the basis of the contrary parts classification, and the lower classification was set aside.

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Issues: Whether liquid crystal displays imported for use in electricity meters were classifiable under Heading 9013 as liquid crystal devices or under Heading 9028 as parts of energy meters, and whether the exemption claim under Notification No. 24/2005-Cus could be denied on the basis of the contrary classification.

Analysis: The appeal turned on the proper application of Chapter Note 2 to Chapter 90 and the tariff scheme for liquid crystal devices. The controlling reason was that liquid crystal displays are specifically provided for under Heading 9013, and when a good is specifically classifiable under its own heading, the rule for classifying parts and accessories with the final machine does not override that specific entry. The earlier tribunal view on which the adjudication order rested had already been reversed by the Supreme Court, which held that the mere use of the displays in electricity meters did not shift them to Heading 9028, because the specific heading for such goods remained Heading 9013.

Conclusion: The goods were correctly classifiable under Heading 9013.80 and not under Heading 9028, so the impugned order could not stand and the appeal succeeded.

Final Conclusion: The classification adopted by the lower authorities was set aside, and the importer obtained the relief sought on the tariff classification issue.

Ratio Decidendi: Where goods are specifically covered by a tariff heading, their use as parts of another machine does not displace the specific heading, and the parts-and-accessories rule applies only when specific classification is otherwise unavailable.

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