Folding cotton fabrics through grooved rollers was not manufacture or calendering, so exemption remained available.

Folding of cotton fabrics through grooved rollers was held to be only a packing convenience and not calendering or manufacture, because no new product came into existence. The rollers were treated as incidental to packing rather than a legal calendering process. As the fabrics had not undergone manufacture, the exemption under the relevant notifications remained available and the duty demand could not be sustained.

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Issues: Whether the folding of cotton fabrics through grooved rollers amounted to calendering or manufacture so as to deny the benefit of exemption under the relevant notifications.

Analysis: The process was found to be only folding of already manufactured fabric for convenience in packing and sale, and not a process bringing into existence a new product. The use of grooved rollers was treated as incidental to packing and not as calendering in the legal sense. Since the fabrics had not undergone a manufacturing process, the exemption remained available and the duty demand could not be sustained.

Conclusion: The activity did not amount to manufacture or calendering, and the assessee was entitled to the exemption.

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