Snap fasteners treated as buttons for customs exemption, with purposive interpretation favouring export manufacture.

Snap fasteners imported for use in garments were treated as buttons for exemption under Notification No. 21/2002-Customs. The analysis follows the purposive view that press buttons or snap fasteners, once assembled on garments, perform the function of buttons and the exemption should support export manufacture rather than be read narrowly. Prior decisions had already settled this interpretation, and departmental reliance on Circular No. 44/2007 did not alter that position. The result was that the exemption applied to the imported snap fasteners and the Revenue challenge failed.

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Issues: Whether snap fasteners imported for use in garments were eligible for exemption as buttons under Notification No. 21/2002-Customs dated 01.03.2002.

Analysis: The dispute turned on whether the imported snap fasteners could be treated as buttons for the purpose of the exemption entry. The earlier judicial view accepted that press buttons or snap fasteners, when assembled on garments, function as buttons and that the exemption notification should be construed to advance its object of facilitating export manufacture rather than defeat it. The issue had already been settled by prior decisions and followed consistently, and the departmental reliance on Circular No. 44/2007 did not displace that settled position.

Conclusion: Snap fasteners were held to be entitled to the benefit of Notification No. 21/2002-Customs dated 01.03.2002, and the Revenue's challenge failed.

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