Tariff classification of dies used in stamping operations: Heading 8207 upheld over Heading 8462.

Dies manufactured and captively used for cold pressing or stamping of metal sheets were examined for tariff classification under the Central Excise Tariff Act, 1985. Heading 8207 covers tools used for pressing, stamping, punching and similar operations, as reflected in the HSN Explanatory Notes, while dies and punches not specifically covered there may fall as parts of the machines or appliances for which they are used. On the facts, the dies were used in stamping operations, so classification under Heading 8207 was maintained and Revenue's claim for Heading 8462 was rejected.

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Issues: Whether dies manufactured and captively used for cold pressing or stamping of metal sheets were classifiable under Heading 8207 or under Heading 8462 of the Schedule to the Central Excise Tariff Act, 1985.

Analysis: Heading 8207 covers tools unsuitable for independent use but designed to be fitted into hand tools, and also machine tools and appliances used for pressing, stamping, punching and similar operations, as reflected in the HSN Explanatory Notes. Dies, punches and other tools not specifically covered by those notes are classified as parts of the machines or appliances for which they are used. On the facts, the dies in question were used in stamping operations and the impugned classification under Heading 8207 did not call for interference.

Conclusion: The dies were not classifiable under Heading 8462 as contended by Revenue; the classification under Heading 8207 was upheld.

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