Specific tariff classification prevails over general parts headings for LCD panels under customs law.

Classification under the Customs Tariff Act depends on the wording of the headings read with the relevant Section and Chapter Notes. Rule 1 gives primacy to the heading text and notes, and Rule 3(a) requires the most specific description to prevail over a general one. LCD panels expressly covered by tariff item 9013.8010 as liquid crystal devices could not be displaced by broader parts-and-accessories headings 8529 or 8522. Chapter 85 Note 1(m) excluded articles of Chapter 90, and Note 2(b) applied only where no specific heading already covered the goods. The principal-use argument could not override that tariff structure.

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Issues: Whether imported LCD panels were classifiable under tariff item 9013.8010 as liquid crystal devices, or under headings 8529 or 8522 as parts suitable for use solely or principally with television or car audio apparatus.

Analysis: Classification under the First Schedule to the Customs Tariff Act, 1975 must be determined by the terms of the headings read with the relevant Section and Chapter Notes. Rule 1 gives primacy to the heading text and notes, while Rule 3(a) requires the heading with the most specific description to prevail over a more general description. Note 1(m) to Chapter 85 excludes articles of Chapter 90, and Note 2(b) to Chapter 85 operates only in respect of parts and accessories that are not already covered by a specific heading. The LCD panels were themselves specifically covered by tariff item 9013.8010. The rival headings 8529 and 8522 were broader part-based entries and could not displace the specific description in Chapter 90. The principal-use argument was rejected because it would override the exclusionary structure of the tariff and render the specific LCD entry redundant.

Conclusion: The goods were correctly classifiable under tariff item 9013.8010 and not under headings 8529 or 8522.

Final Conclusion: The revenue's challenge failed because the specific tariff entry for liquid crystal devices prevailed over the competing part-based headings, and the classification adopted by the Tribunal was upheld.

Ratio Decidendi: Where goods are expressly described in a specific tariff entry, that entry prevails over a general parts-and-accessories entry, and exclusionary chapter notes cannot be overridden by a principal-use argument unless the specific heading is inapplicable.

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