Cladding for SSI exemption requires permanent bonding; adhesive PVC attachment to MS sheets was held not to qualify.

SSI exemption for flat rolled iron and steel products applied only where the goods were truly clad. Cladding required a permanent bonding or covering of one material with another, ordinarily involving molecular interpenetration or welding, not a surface attachment that could be easily separated. Because the PVC film was fixed by adhesive and roller pressure and could be peeled off from the MS sheets, the product did not satisfy the meaning of cladding under Notification No. 1/93-C.E. and was held ineligible for the exemption.

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Issues: Whether the product, being galvanized MS sheets with PVC sheet pasted on one side, was a clad product eligible for exemption under SSI Notification No. 1/93-C.E. dated 28-2-1993.

Analysis: The benefit of the notification was available only to flat rolled products of iron and steel clad. Cladding connotes a process of bonding or covering one material with another with a degree of permanence, ordinarily involving molecular interpenetration or welding of the surfaces in contact. On the facts found, the PVC film was applied by adhesive and roller pressure and could be easily separated from the MS sheets. Such a process did not answer the description of cladding under the notification or the HSN guidance relied upon.

Conclusion: The product was not a clad product and was therefore not eligible for the benefit of Notification No. 1/93-C.E. The Revenue's appeal succeeded.

Ratio Decidendi: A product is not "clad" for purposes of SSI exemption unless the bonding between the layers is of a permanent character amounting to true cladding, not merely adhesive attachment capable of easy separation.

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