Woven cotton and woollen felts fall within fabric tariff entries because weave, not end use, determines classification.

Woven cotton and woollen felts were treated as fabrics for excise classification under Tariff Items 19 and 21 because the tariff language covered all varieties of cotton and wool fabrics, and the decisive test was whether the material was woven, not its end use. The distinction drawn in the earlier Supreme Court ruling on non-woven felts was held inapplicable, since that principle addressed non-woven material. A Punjab High Court sales tax decision was also distinguished as concerning a different taxing entry. Trade affidavits did not displace the classification because the goods remained fabrics despite being specialised products.

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Issues: Whether cotton and woollen felts manufactured by the petitioners were classifiable as cotton fabrics and woollen fabrics under Tariff Items 19 and 21, and whether earlier decisions treating non-woven felts as non-fabric applied to woven felts.

Analysis: Tariff Items 19 and 21 cover all varieties of fabrics manufactured wholly or partly from cotton or wholly of wool, and the scope of the entries was held to be wide enough to include woven materials irrespective of their end use. The earlier Supreme Court decision relied upon dealt with non-woven felts, and the principle stated there was that fabric means woven material; it did not govern the present case because the goods in question were admitted to be woven. The Punjab High Court decision concerned a different taxing entry under sales tax law and was not considered apposite for construing the excise tariff entry. The affidavits from traders were rejected as not showing that the goods ceased to be fabrics merely because they were specialized products and not garments or covering materials.

Conclusion: The cotton and woollen felts were held to be fabrics and were classifiable under Tariff Items 19 and 21 respectively, with the duty liability upheld against the petitioners.

Ratio Decidendi: Woven textile products are fabrics within the tariff entries even when they are specialized goods and not used as garments or covering materials; the decisive test is whether the material is woven, not its end use.

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