Loose stock awaiting further processing cannot be treated as fully manufactured goods for duty liability.

Loose stock of fabrics described as awaiting dyeing or further processing in the finishing room RG-1 entry could not be treated as fully manufactured goods liable to excise duty. The record showed physical verification by the department, but the material was identified as unfinished stock and there was no evidence that the entire quantity had reached final manufacture or was actually lying in the BSR column as alleged. On those facts, goods pending further processing were outside duty liability, and the Revenue's case failed.

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Issues: Whether the loose stock of fabrics stated to be lying in water or awaiting dyeing and shown in the finishing room RG-1 entry could be treated as fully manufactured goods liable to duty.

Analysis: The quantity in question was physically verified by the department, and the record showed that it was described as loose stock awaiting further processing rather than finished goods. No evidence was produced to establish that the entire quantity was fully finished or that it was actually lying in the BSR column as alleged. On the facts found, goods awaiting further processing could not be treated as fully manufactured for duty purposes.

Conclusion: The loose stock was not liable to duty, and the Revenue's appeal failed.

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