Thank you John, I have the document and I agree, I see the same.
You know, the document clearly defines wear & tear items as "consumable items" (4.1 e) If that is the case headlight adjusters are not consumable items.
I forgot to mention that they sent an independent engineer to visit and he said that wear & tear caused the headlight adjusters to stop working. I guess that still doesn't make a valid reason for refusal as its not a consumable item, or does it?