Specific tariff description prevails for precious-metal sputtering targets, keeping them under Chapter 71 and defeating Chapter 85 classification.

Sputtering targets containing precious metal were classified under Chapter 71 of the Customs Tariff Act, 1975 because Rule 3(a) of the General Rules for Interpretation and Chapter Note 1(b) required the more specific tariff description to prevail. The goods were treated as articles of precious metal with an independent identity, rather than as machine parts falling under Chapter 85. A notification referring to silver sputtering targets under Chapter 71 supported that classification, although the operative basis remained the tariff notes and interpretative rules. As a result, the goods were not eligible for treatment under Chapter 85, and the drawback claim was upheld as rejected.

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Issues: Whether sputtering targets were correctly classified under Chapter 71 of the Customs Tariff Act, 1975, and consequently whether the drawback claim was payable.

Analysis: The classification dispute was resolved by applying Rule 3(a) of the General Rules for the Interpretation of the Harmonized System of Nomenclature, under which the heading giving the most specific description is preferred. Chapter Note 1(b) of Chapter 71 of the Customs Tariff Act, 1975 required articles consisting wholly or partly of precious metal or metal clad with precious metal to be classified in that chapter. On the facts recorded, the goods were treated as sputtering targets of precious metal, having an independent identity and not forming part of the machine under Chapter 85. The notification mentioning silver sputtering targets under Chapter 71 also supported that view, though classification itself had to follow the tariff notes and interpretative rules.

Conclusion: The goods were held classifiable under Chapter 71 and not under Chapter 85, so the rejection of the drawback claim was upheld.

Ratio Decidendi: Where tariff notes and the interpretative rules specifically bring goods within a chapter, classification must follow that specific tariff treatment rather than a broader machine-part heading.

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