Job work exemption under Customs notification denied where importer used substantial own materials, not merely imported goods for re-export.

Imported fabrics did not qualify for exemption under Notification No. 32/97-Cus because the import was not for jobbing in the manner required by the notification. The goods were used only for edging jute carpets, while the basic carpet material was arranged locally by the importer, showing that the activity involved substantial use of the importer's own materials rather than mere processing of imported goods for re-export under an export order placed by the supplier. The job work interpretation applied in the excise exemption context supported this restrictive reading, and the exemption was denied.

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Issues: Whether the imported fabrics were eligible for exemption under Notification No. 32/97-Cus dated 01.04.1997 as goods imported for execution of an export order placed on the importer by the supplier of the goods for jobbing.

Analysis: The imported material was used only for edging jute carpets procured locally by the importer, while the basic carpet material was not imported but arranged by the importer itself. The condition in the notification required import for jobbing, with the imported goods and resultant product being re-exported pursuant to an export order placed by the supplier. The arrangement did not satisfy that requirement, because the importer contributed substantial own material and the activity was not confined to jobbing as contemplated by the notification. The interpretation placed on job work in the excise exemption context in Notification No. 119/75-CE supported this view, since that exemption was not intended to cover cases where the manufacturer supplied its own material and produced different goods.

Conclusion: The benefit of Notification No. 32/97-Cus was not available to the importer. The appeal failed.

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