Mere dressing of raw lamb skin is not manufacture, so Chapter 43 duty classification failed for want of proof.

Mere dressing of fresh slaughtered lamb skins with oil to prevent deterioration does not amount to manufacture or convert raw skin into a new marketable commodity. As the goods were not shown by evidence or expert opinion to have undergone tanning or any comparable process, they could not be classified as manufactured fur skins under Chapter 43 for additional duty or SAD. The burden to prove the duty-attracting classification lay on the Revenue, and it was not discharged. The importer's classification was accepted and the duty demand based on Chapter 43 was not sustained.

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Issues: Whether imported dressed fur skin of lamb was a manufactured fur skin classifiable under Chapter 43 so as to attract additional duty or SAD, or whether it remained a raw dressed skin exempt from such levy.

Analysis: The imported goods were found to be fresh slaughtered lamb skins merely dressed with oil to prevent deterioration and decay. Such dressing was held not to amount to manufacture, as it did not convert the raw skin into a new manufactured marketable commodity by tanning or any comparable process. The Revenue failed to adduce evidence, including expert opinion, to show that the goods had undergone manufacture. The burden of proving the classification attracting duty rested on the Revenue, and that burden was not discharged.

Conclusion: The goods were not manufactured fur skins and did not fall under Chapter 43 for levy of additional duty or SAD. The importer's classification was accepted and the Revenue's appeal was rejected.

Final Conclusion: The duty demand based on classification under Chapter 43 was not sustained, and the exemption position claimed by the importer was upheld.

Ratio Decidendi: Mere dressing of raw animal skin for preservation does not constitute manufacture unless it results in a new marketable commodity, and the Revenue must prove the contrary for duty classification.

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