Tariff entry for dies read narrowly, excluding forged dies from central excise duty coverage.

Tariff Item 51A(iii) was construed according to its express wording, which covered dies for wire drawing and extrusion dies for metal and rock drilling bits, and not dies generally. On that interpretation, forged dies manufactured by the assessee did not fall within the entry. The central excise duty demand based on Tariff Item 51A(iii) therefore could not be sustained.

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Issues: Whether forged dies manufactured by the assessee fell within Tariff Item 51A(iii) so as to attract central excise duty.

Analysis: The dispute turned on the interpretation of Tariff Item 51A(iii), which specifically covered dies for wire drawing and extrusion dies for metal and rock drilling bits. As the tariff item did not use a broad expression such as all dies, the category had to be read according to its express wording. On that construction, forged dies were not encompassed by the entry.

Conclusion: Forged dies were held to be outside the ambit of Tariff Item 51A(iii), and the duty demand on that basis could not be sustained.

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