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Issues: Whether ceramic nozzles used in welding machines are classifiable under Heading 69.01 as ceramic/refractory nozzles or under Heading 85.15 as parts of welding machines.
Analysis: Heading 69.01 specifically covers ceramic nozzles, while Heading 85.15 is a general heading for parts of welding machines. Under Rule 1 of the Rules for the Interpretation of the Schedule to the Central Excise Tariff Act, classification is determined according to the terms of the headings and relevant section or chapter notes. The presence of Note 2(b) to Section XVI did not displace the specific coverage of the goods under Heading 69.01, because there was no section or chapter note excluding ceramic nozzles from Chapter 69. Applying the principle that a specific entry prevails over a general entry, the more specific description had to govern.
Conclusion: Ceramic nozzles are classifiable under Heading 69.01 and not under Heading 85.15. The issue is decided in favour of the Revenue.
Ratio Decidendi: Where a tariff heading specifically names the goods, that specific description prevails over a more general heading for parts of machinery, and classification must follow the heading terms read with the relevant interpretative rules and notes.