Tariff classification of asbestos gaskets turns on direct manufacture from mineral fibres, not products made through intermediate sheets.

Conversion of duty-paid asbestos jointing sheets into non-automotive gaskets was accepted as manufacture under Section 2(f) of the Central Excises and Salt Act, 1944, but classification turned on the wording of Item 22F(iv). The entry covered manufactures made directly from mineral fibres and yarn, and did not extend to goods made from asbestos sheets that had themselves been manufactured from fibre or yarn. Because the gaskets were not direct manufactures from mineral fibres or yarn, and no other specific tariff entry applied, they were classifiable under the residuary Item 68.

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Issues: Whether non-automotive gaskets cut out of asbestos jointing sheets are classifiable under Item 22F(iv) of the First Schedule to the Central Excises and Salt Act, 1944 or under the residuary Item 68.

Analysis: The conversion of duty-paid asbestos gasketing sheets into gaskets was accepted as manufacture under Section 2(f) of the Central Excises and Salt Act, 1944. The dispute was whether the finished gaskets were manufactures therefrom within Item 22F(iv). The decisive consideration was the wording of the tariff entry, which covered manufactures directly from mineral fibres and yarn. Gaskets made from asbestos sheets, although the sheets themselves were manufactured from fibre or yarn, were not direct manufactures from fibre or yarn. The entry did not use broader language such as manufactures containing or comprising fibre or yarn. Since the goods were not covered by the specific entry and were not otherwise specified in the tariff, they fell to be classified under the residuary item.

Conclusion: Non-automotive gaskets made out of asbestos sheets do not fall under Item 22F(iv) and are classifiable under Item 68.

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