Textile processing under Chapter Note 4: carding, knitting and back-coating were not manufacture, preserving exemption from duty.

Carding, knitting, shearing and back-coating on knitted pile fabric were held not to amount to manufacture under Chapter Note 4 to Chapter 60 because that note covers only specified textile processes and processes of the same kind. The record showed no bleaching, mercerising, dyeing, printing, waterproofing, shrink-proofing, tentering, heat-setting, or analogous process, and no evidence of drying through a hot air chamber or similar machine. The words "any other process" were read ejusdem generis with the listed processes. Prior payment of duty did not bar the claim to exemption when the fabric remained unprocessed, so the goods were treated as exempt from duty.

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Issues: Whether the processes of carding, knitting, shearing and back-coating undertaken on knitted pile fabric amounted to manufacture under Chapter Note 4 to Chapter 60 of the Central Excise Tariff Act, 1985, and whether the goods were entitled to exemption under the relevant notifications.

Analysis: Chapter Note 4 treats only specified textile processes and processes of the same kind as manufacture. The processes found on the record did not include bleaching, mercerising, dyeing, printing, waterproofing, shrink-proofing, tentering, heat-setting or any analogous process, and there was no evidence of drying through a hot air chamber or similar machine. The broader words "any other process" had to be read ejusdem generis with the listed processes. Earlier payment of duty did not create an estoppel against claiming exemption when the product was found to remain unprocessed.

Conclusion: The processes did not amount to manufacture and the knitted pile fabric remained exempt from duty.

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