Exemption notification interpretation: dies for drawing metal strips were covered as machine-tool fittings under Chapter 82.

Dies for drawing metal strips were held to fall within Notification No. 58/86-C.E. as tools designed to be fitted into machine tools and classifiable under Chapter 82. The expression "including" in the notification was treated as illustrative, not restrictive, so the specific reference to dies for wire drawing and extrusion dies for metals did not exclude other dies that otherwise satisfied the main description. On that basis, the exemption was available and denial of the benefit was not sustainable.

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Issues: Whether dies for drawing metal strips were covered by Notification No. 58/86-C.E. as tools designed to be fitted into machine tools and thus eligible for exemption.

Analysis: The notification exempted tools designed to be fitted into hand tools or machine tools and specifically mentioned dies for wire drawing and extrusion dies for metals under Chapter 82. The goods in question were found to be tools designed to be fitted into machine tools and classifiable under Chapter 82. The use of the word "including" in the notification was treated as illustrative rather than restrictive, so the express mention of certain dies did not exclude dies for drawing strips from the exemption where they otherwise fell within the main entry.

Conclusion: The dies for drawing metal strips were covered by the exemption notification and the denial of benefit was unsustainable; the issue is decided in favour of the assessee.

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