Noscitur a sociis limits "any other process": cropping grey fabrics is not manufacture and no duty consequence follows.

Cropping of grey cotton and man-made fabrics was analysed under Chapter Note 3 of Chapter 52 and Chapter Note 4 of Chapter 55 to determine whether it amounted to "any other process" constituting manufacture. Applying noscitur a sociis, the note was read with the listed processes such as bleaching, mercerising, dyeing and printing, and cropping was treated as a mere mechanical finishing operation that did not cause a permanent change, create a new commercially different product, or fall within the same genus. Cropping therefore did not amount to manufacture, the fabrics remained grey fabrics, and the duty demand and penalty could not stand.

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Issues: Whether the process of cropping undertaken on grey cotton and man-made fabrics amounts to "any other process" so as to constitute manufacture under Chapter Note 3 of Chapter 52 and Chapter Note 4 of Chapter 55 of the Central Excise Tariff Act, 1985, and thereby disentitle the goods from exemption.

Analysis: The relevant chapter notes use illustrative processes such as bleaching, mercerising, dyeing, printing and similar treatments, and the expression "any other process" must be read in the same genus by applying the principle of noscitur a sociis. Cropping was found to be a mechanical process of cutting away loose ends and projecting fibres to give a clean and smooth appearance. It did not bring about any permanent change in the character of the grey fabric, did not create a new and commercially different product, and was not of the same kind as the processes expressly mentioned in the chapter notes. The reasoning was supported by the line of decisions treating shearing and similar finishing operations as not amounting to manufacture where no lasting change is caused.

Conclusion: Cropping does not fall within "any other process" in the relevant chapter notes and does not amount to manufacture; the fabrics remained grey fabrics and the demand of duty and penalty could not stand.

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