Broad interpretation of "sawing machines" extends customs exemption to laser-based diamond sawing equipment used in jewellery processing.

Notification No. 159/86-Cus. granted concessional customs duty to specified goods used in the manufacture and processing of gem and jewellery, subject to prescribed conditions. The expression "sawing machines" in serial number 58 was broad enough to include modern laser-based diamond sawing machines, and the separate reference elsewhere in the notification to laser drilling machines did not narrow that entry. As the imported machine was used for the notified purpose and the other conditions were satisfied, it qualified for exemption under the notification, and the Revenue's challenge failed.

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Issues: Whether the imported laser-based diamond sawing machine was covered by the expression "sawing machines" in Notification No. 159/86-Cus. dated 1-3-1986 and entitled to concessional customs duty benefit.

Analysis: The notification granted concessional duty to goods specified in the annexed table for use in the manufacture and processing of gem and jewellery, subject to prescribed conditions. The entry at serial number 58 covered "sawing machines" without qualification. The goods were imported for the purposes contemplated by the notification, and the other conditions were found to have been satisfied. The expression "sawing machines" was held to be broad enough to include modern laser-based diamond sawing machines, and the specific reference elsewhere in the notification to laser drilling machines did not narrow the scope of the sawing-machine entry.

Conclusion: The laser diamond sawing machine was entitled to exemption under Notification No. 159/86-Cus. The Revenue appeals failed.

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