Clothing accessories exemption cannot be stretched to cover socks when the notification omits them

Socks classified under the tariff heading for clothing accessories were held not to qualify for exemption under Notification No. 6/2002-C.E. because the notification listed specific items such as handkerchiefs, gloves, shawls, scarves, mufflers, ties, bow-ties, cravats, mittens and mitts, but did not mention socks. The general expression "clothing accessories" could not be expanded to include an item specifically omitted from the exemption entry. Reliance on the earlier decision was found inapplicable on the facts, and the exemption benefit was denied.

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Issues: Whether socks manufactured by the appellants were entitled to exemption under Notification No. 6/2002-C.E. as clothing accessories.

Analysis: The relevant tariff heading for clothing accessories expressly includes socks and stockings, but the exemption notification is confined to specific clothing accessories such as handkerchiefs, gloves, shawls, scarves, mufflers, mantantas, veils, ties, bow-ties, cravats, mittens and mitts. Socks are not mentioned in the notification. The general description of clothing accessories in the exemption notification could not be enlarged to cover socks when the notification specifically omitted them. The reliance placed on the earlier decision was held to be inapplicable on the facts.

Conclusion: Socks were not covered by the exemption notification and the denial of benefit was upheld.

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