PUREWALL AND ASSOCIATES LTD Vs. COLLECTOR OF CUSTOMS

JUDGEMENT

(1.) THE question that falls for decision in this case is whether Press Tools, which on examination were found to be die sets, fall under heading No. 82.05 of the Customs Tariff Act, 1975, as held by the lower authorities, or under heading No. 84.45/48, as urged by the appellants.

(2.) THE samples of the subject die sets were shown to us during the hearing. There is no dispute on the facts of the case. Both sides agree that these die sets are intended to be fitted to power presses installed in the appellants' factory for manufacture of watch parts. There is also agreement that one die set can manufacture a particular watch part only. The crucial point for our determination is whether these die sets can be considered as interchangeable tools for the purpose of heading 82.05.

(3.) THE appellants' pleas are two fold :