Direct manufacture tariff entry held limited to goods made from specified material; intermediate products were excluded.

A tariff entry using the words "manufacture therefrom" was construed to cover only goods directly manufactured from the specified mineral fibres or yarn, read together with the accompanying description of products in which those materials predominate. The Court rejected an interpretation that would extend the entry to later-stage products made from an intermediate commodity in which mineral fibres had earlier been used, as that would distort the tariff scheme. On that construction, tubular arc chamber housings made from glass fabric were held outside Tariff Item 22F(4) and liable under the residuary Tariff Item 68, with the issue decided in favour of the assessee.

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Issues: Whether tubular shaped arc chamber housings manufactured from glass fabric were classifiable under Tariff Item No. 22F(4) of the Central Excise Tariff Act or under the residuary Tariff Item No. 68.

Analysis: The entry was read as consisting of a descriptive part and an explanatory part, both to be construed together. The phrase "manufacture therefrom" was held to cover goods manufactured from mineral fibres or yarn, and the words "other manufactures in which mineral fibres or yarn or both predominate" enlarged the entry only to that limited extent. The construction could not be extended to products made from an intermediate commodity in which mineral fibre or yarn had earlier been used. An interpretation treating every later-stage product as covered would alter the scheme of the tariff item and was rejected.

Conclusion: The arc chamber housings were not classifiable under Tariff Item No. 22F(4) and were exigible to duty under the residuary Tariff Item No. 68; the issue was decided in favour of the assessee.

Ratio Decidendi: A tariff entry using the expression "manufacture therefrom" covers only goods directly manufactured from the specified material, and an extension based on prior use of that material in an intermediate product is not permissible unless the entry clearly so provides.

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