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(viii) materials means goods which are raw materials, components, intermediate products or consumables used in the manufacture of resultant products and their packings, or mandatory spares to be exported alongwith the resultant products."

Shri Subba Rao has laid emphasis on the words "used in the manufacture of in clause (viii) and has urged that for availing the exemption it is necessary that the material must be required for use in the manufacture of resultant products. Shri Subba Rao has also invited our attention to the decision of this Court in The Tata Oil Mills Co. Ltd vs. Collector of C. Ex. 1989 43 ELT. 183, wherein in the matter of interpretation of a notification granting exemption from payment of duty this court had said :

It is true that in clause (viii) of the Explanation to the Notification expression 'materials' has been defined to mean goods which are raw materials, components, intermediate products or consumables used in the manufacture of resulting products and their packings or mandatory spares to be exported in the resultant products. But the said definition in the Explanation has to be read in consonance with the main part of the notification. It is a well settled principle of statutory construction that the Explanation must be read so as to harmonise with and clear up any ambiguity in the main provision. [See: Bihta Cooperative Development Cane Marketing Union Ltd. & Anr. vs. The Bank of Bihar & Ors. 1967(1) SCR 848 at p.854]. The definition of "materials" in clause (viii) of the Explanation must, therefore, be so construed as not to climinate the distinction between the words 'materials required for the purpose of manufacture of products' and the words 'materials used in the manufacture of the resultant products' in the main part of the definition.