Specific tariff classification prevails over general parts heading for liquid crystal devices used in LCD televisions.

Imported liquid crystal devices are classified under Heading 9013 80 10 when they are specifically described by that tariff entry, and they do not move to Heading 8529 merely because they are used as parts of LCD televisions. The analysis turns on relative specificity: a named and exclusive heading prevails over a general parts heading. Section Note 2 of Section XVI was found inapplicable because the dispute lay in Chapter 90, and Note 1(m) excluded Chapter 90 articles from Section XVI. The reasoning was reinforced by prior and later Supreme Court authority supporting classification under the specific heading. The assessee obtained relief and the Revenue's classification was rejected.

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Issues: Whether imported liquid crystal devices were classifiable under Heading 9013 80 10 as liquid crystal devices, or under Heading 8529 as parts suitable for use solely or principally with LCD televisions.

Analysis: The dispute turned on the relative specificity of the competing tariff entries. Liquid crystal devices are expressly named in Heading 9013, and sub-heading 9013 80 10 is exclusively carved out for such devices. Heading 8529, by contrast, is a general parts heading for goods suitable for use with apparatus of Headings 8525 to 8528. The prior decision between the same parties had already held that when an article is specifically covered by Heading 9013, its use as a part of LCD televisions does not make Heading 8529 more specific. The reliance placed on Section Note 2 of Section XVI did not assist the Revenue because that note governs Chapter 84 and 85, whereas the classification issue here fell within Chapter 90. Note 1(m) of Section XVI also excluded articles of Chapter 90 from that section. The later Supreme Court ruling on liquid crystal devices supported the same approach by treating LCDs as classifiable in their specific heading.

Conclusion: The imported goods were classifiable under Heading 9013 80 10 and not under Heading 8529.

Final Conclusion: The assessee succeeded and the classification adopted by the Revenue was set aside, with consequential relief following.

Ratio Decidendi: Where goods are specifically described in a tariff heading, they are classifiable under that specific entry and cannot be shifted to a more general parts heading merely because they are used with another apparatus.

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