Ejusdem generis limits textile manufacture clause, so carding and back-coating on fabric did not attract duty.

Processes on knitted pile fabric such as carding, knitting, shearing and back-coating were not treated as manufacture under Chapter Note 4 to Chapter 60 because they were neither expressly covered nor shown to be processes of the same genus as those listed. The expression "any other process" was construed by ejusdem generis, limiting it to similar textile processes. On the facts, the fabric remained unprocessed, and prior payment of duty did not bar exemption. The duty demand was therefore held unsustainable, and the assessee was entitled to the relevant exemption notifications.

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Issues: Whether the processes of carding, knitting, shearing and back-coating undertaken on knitted pile fabric amounted to manufacture under Chapter Note 4 to Chapter 60 of the Central Excise Tariff Act, 1985, so as to make the goods dutiable, and whether the assessee was entitled to exemption under the relevant notifications.

Analysis: Chapter Note 4 treats specified textile processes, and any other process of the same genus, as manufacture. The processes adopted by the assessee were carding, knitting, shearing and back-coating. These processes were not specifically covered by the note, nor were they shown to be analogous to the listed processes. The record also did not show that drying of the back-coated fabric was carried out through a hot air chamber or similar machine. The principle of ejusdem generis was applied to construe the expression 'any other process' in line with the specified processes. On the facts, the fabric remained unprocessed, and the earlier payment of duty did not create any estoppel against claiming exemption.

Conclusion: The processes did not amount to manufacture under Chapter Note 4 to Chapter 60, and the assessee was entitled to exemption under the notifications; the duty demand was not sustainable.

Final Conclusion: The appellate challenge failed because the goods were held to be unprocessed and not liable to duty on the facts proved in the record.

Ratio Decidendi: For textile goods, 'any other process' in a manufacture clause is confined by ejusdem generis to processes similar to those expressly listed; if the revenue fails to prove such similarity, the activity does not amount to manufacture.

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