Lamination did not alter the identity of cement bonded particle boards, so the exemption continued to apply.

Lamination of cement bonded particle boards did not change their essential character or create a new product; the Tribunal treated the laminated boards as continuing to be cement bonded particle board. As the difference between laminated and un-laminated boards was only a marketing distinction reflected in brand naming, it did not justify a different classification or denial of exemption. The Tribunal also reiterated that not every process amounts to manufacture of new goods. The exemption available to cement bonded particle board was therefore held to extend to the laminated boards.

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Issues: Whether cement bonded particle laminated boards retained their identity as cement bonded particle board and remained eligible for the exemption granted to cement bonded particle board.

Analysis: The Tribunal held that lamination did not alter the essential character of the goods. Even after further processing, the product continued to be cement bonded particle board. The mere use of different brand names for laminated and un-laminated boards was treated as a marketing distinction and not as a basis for changing classification or denying exemption. It was also reiterated that not every process amounts to manufacture of new goods.

Conclusion: The exemption was held to be available to the laminated boards, and the issue was decided in favour of the assessee.

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