Tariff classification of impregnated fabrics and paper turns on statutory definitions, while distinct manufactures may fall to the residuary entry.

Tariff classification depends on the express statutory description where the entry itself includes treated, impregnated or laminated goods, and not on common parlance. Resin-impregnated cotton fabric was held to fall within the cotton fabrics entry because the tariff definition expressly covered fabrics impregnated with artificial plastic materials, so classification under Tariff Item 19(III) was upheld. Resin-impregnated paper was likewise held to remain within the paper entry because the tariff specifically covered impregnated paper, so Tariff Item 17(2)/17(1) applied. Glass fabric-based Prepeg-G, however, was treated as a distinct further manufacture outside the mineral fibres entry and was classifiable under the residuary item.

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Issues: (i) Whether resin-impregnated cotton fabric known as Prepeg-F fell under Tariff Item 19(III); (ii) whether resin-impregnated paper known as Prepeg-P fell under Tariff Item 17(2)/17(1); and (iii) whether glass fabric based Prepeg-G fell under Tariff Item 22-F/22-F(4) or the residuary Item 68.

Issue (i): Whether resin-impregnated cotton fabric known as Prepeg-F fell under Tariff Item 19(III).

Analysis: The tariff entry defined cotton fabrics in inclusive terms and expressly covered fabrics impregnated, coated or laminated with preparations of cellulose derivatives or other artificial plastic materials. The common parlance test was inapplicable where the statute itself contained a definition. The product was a cotton fabric impregnated with synthetic resin, and resin was treated as an artificial plastic material for the purposes of the entry.

Conclusion: Prepeg-F was correctly classifiable under Tariff Item 19(III), and the finding was in favour of the Revenue.

Issue (ii): Whether resin-impregnated paper known as Prepeg-P fell under Tariff Item 17(2)/17(1).

Analysis: The relevant tariff entries expressly included paper and paper board subjected to treatment such as coating and impregnating. Marketability or trade nomenclature could not exclude a product from an entry that specifically covered impregnated paper. Resin-impregnated paper used for laminated sheets remained within the ambit of the inclusive paper entry.

Conclusion: Prepeg-P was correctly classifiable under Tariff Item 17(2)/17(1), and the finding was in favour of the Revenue.

Issue (iii): Whether glass fabric based Prepeg-G fell under Tariff Item 22-F/22-F(4) or the residuary Item 68.

Analysis: The mineral fibres entry covered glass fibre, glass yarn and manufactures therefrom, but the scope of the entry did not extend to a further manufacture made from glass fabric. The product was not merely glass fabric; it was a distinct manufacture produced by impregnating glass fabric, and the entry could not be stretched beyond its terms. The residuary entry applied where the product did not fall within the specific tariff item.

Conclusion: Prepeg-G did not fall under Tariff Item 22-F/22-F(4) and was classifiable under Tariff Item 68, in favour of the Assessee.

Final Conclusion: The tariff classification was upheld for Prepeg-F and Prepeg-P, but the classification of Prepeg-G under the mineral fibres entry was rejected and the residuary entry was applied instead.

Ratio Decidendi: Where a tariff entry expressly includes treated, impregnated or laminated goods, classification must follow the statutory definition rather than common parlance, but a residuary entry applies when a further manufactured product falls outside the specific scope of the applicable tariff item.

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