Tariff classification of moulds and die casting dies fell under the residuary entry, not the specific tools item.

Moulds and die casting dies were held not to fall within Tariff Item 51-A, because that entry was construed as a limited and specific provision covering only the tools expressly named in its sub-items. A broad reading of the words "tools" and "dies" was rejected, and the tariff was to be applied on the plain language of the entry rather than extraneous opinion. As the goods were not covered by Item 51-A, they were classifiable under the residuary Tariff Item 68.

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Issues: Whether moulds and die casting dies manufactured by the petitioner were classifiable under Tariff Item No. 51-A or under the residuary Tariff Item No. 68 of the Schedule to the Central Excises and Salt Act, 1944.

Analysis: Tariff Item No. 51-A was held to be a limited and specific entry covering only the tools expressly named in its sub-items. The expressions in that item did not naturally include moulds, and the departmental attempt to place the goods within sub-item (iii) on the basis of a broad understanding of the words "tools" and "dies" was rejected. The proper approach was to read the tariff entry by its own language and not by extraneous opinions. Since moulds and die casting dies were not covered by Item 51-A, they fell to be considered under the residuary item.

Conclusion: The moulds and die casting dies were not exigible under Tariff Item No. 51-A and were classifiable under Tariff Item No. 68.

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