Classification of dies as machine parts under Heading 84.66 where they were not dies for drawing or extruding metal.

Dies used for operations such as deep drawing, bending, cutting, punching and slotting, rather than for drawing or extruding metal, fall outside Heading 82.07, which covers interchangeable tools including only dies of that specific kind. Applying the HSN Explanatory Notes, dies not covered by Heading 82.07 are classified as parts of the machines for which they are intended. On that basis, dies intended for press machines used in manufacturing motor vehicle parts were classifiable under Heading 84.66 as machine parts, and the exemption claimed under Notification No. 58/86-C.E. did not survive.

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Issues: Whether the dies manufactured by the assessee were classifiable under Heading 82.07 of the Central Excise Tariff and entitled to exemption under Notification No. 58/86-C.E., or were correctly classifiable as parts of machines under Heading 84.66.

Analysis: The product was admitted to be dies not used for wire drawing or extruding metal, but for operations such as deep drawing, bending, cutting, punching and slotting. Heading 82.07 covers interchangeable tools, including dies for drawing or extruding metal, and not all types of dies. The HSN Explanatory Notes also indicate that dies and similar interchangeable tools not covered by Heading 82.07 are to be classified as parts of the machines or appliances for which they are intended. Since the dies were intended for press machines used in manufacture of motor vehicle parts, they were classifiable as machine parts.

Conclusion: The dies were not classifiable under Heading 82.07 and were correctly classified under Heading 84.66; the exemption claim did not survive.

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