Tyre cord fabric classification under Heading 5902 excludes later rubber coating and calendering after manufacture is complete.

Tyre cord fabric that has undergone rubber coating and calendering falls outside Heading 5902 of the Central Excise Tariff because that heading covers tyre cord fabric only in its plain, dipped, or impregnated form. The HSN Notes indicate that dipping and impregnating are contemplated processes, but rubber coating and calendering are later operations directed towards tyre manufacture and occur after the tyre cord fabric is already complete. Such post-manufacture processing is not incidental or ancillary to classification under Heading 5902. The issue was therefore answered in favour of the assessees.

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Issues: Whether tyre cord fabric subjected to rubber coating and calendering remained classifiable under Heading 5902 of the Central Excise Tariff.

Analysis: Heading 5902 specifically covers tyre cord fabric, whether or not dipped or impregnated with rubber or plastics. The HSN Notes show that dipping and impregnating are additional processes contemplated for tyre cord fabric, but they do not treat rubber coating or calendering as processes within the manufacture of tyre cord fabric. Those later processes are directed towards building tyres and other products, and therefore occur after the manufacture of tyre cord fabric is complete. Such processing cannot be treated as incidental or ancillary to the manufacture of tyre cord fabric for the purpose of classification under Heading 5902.

Conclusion: Tyre cord fabric subjected to rubber coating and calendering is not classifiable under Heading 5902, and the issue is answered in favour of the assessees.

Ratio Decidendi: For tariff classification, a product does not remain within a specific heading when subsequent processing takes it beyond the scope of manufacture contemplated by that heading, especially where the heading itself covers only the fabric in its plain, dipped, or impregnated form.

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