Tariff classification of dies under Item 51A(iii) upheld as tools designed for machine tools.

Dies described by the assessee as such were held classifiable under Item 51A(iii) of the Central Excise Tariff Schedule because the entry covered tools designed to be fitted into machine tools, and the reference to dies for wire drawing and extrusion did not limit the scope of the sub-item to those examples alone. The belated contention that the goods were merely die blocks was not entertained because it had not been raised before the lower authorities. The classification in favour of the Revenue was upheld.

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Issues: Whether drop forging die, counter blow die and upset die were classifiable under Item 51A(iii) of the Central Excise Tariff Schedule as tools designed to be fitted into machine tools.

Analysis: The goods were described by the assessee itself as dies, and the belated plea that they were only die blocks was not entertained as it had not been raised before the lower authorities. The entry covered all tools designed to be fitted into hand tools or machine tools, and the specific mention of dies for wire drawing and extrusion dies for metals did not confine the scope of the sub-item to those dies alone. On the plain language of the tariff entry, dies which are in the nature of tools designed to be fitted into machine tools also fell within the entry.

Conclusion: The goods were correctly classified under Item 51A(iii), and the classification in favour of the Revenue was upheld.

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