Specific tariff heading prevails for flow meter components; residual classification rules cannot override the more precise description.

Imported components and accessories used solely for a volumetric displacement flow meter were held to follow the same tariff classification as the finished product. The specific heading for flow meters under Heading 90.24 prevailed over the more general heading for supply or production meters under Heading 90.26, because tariff classification must first be determined by the most specific description. Rule 3(c) applies only after the specific-description and essential-character tests fail under Rules 3(a) and 3(b). On that basis, the competing general entry could not displace the specific entry, and the goods were correctly classified under Heading 90.24.

---

---

Issues: Whether imported components and accessories meant for a volumetric displacement type flow meter were classifiable under Heading 90.24 as parts of a flow meter or under Heading 90.26 by application of the general interpretative rules.

Analysis: Heading 90.24 specifically covers flow meters, while Heading 90.26 is a more general entry for supply or production meters. The interpretative scheme gives preference to the heading that provides the most specific description. Rule 3(c) operates only when classification cannot be made under the specific or essential-character tests in Rule 3(a) and Rule 3(b). Since the end product manufactured by the appellant was a flow meter specifically covered by Heading 90.24, the imported components used solely for that product had to take the same classification. The later and more general heading could not displace the specific entry.

Conclusion: The goods were correctly classifiable under Heading 90.24, and the contrary classification under Heading 90.26 was erroneous. The appeal succeeded in favour of the assessee.

Ratio Decidendi: Where goods answer a specific tariff description, that specific heading prevails over a more general competing heading, and the residual rule of classification cannot be invoked unless the prior rules fail.

---