Slitting gummed paper into tapes does not amount to manufacture and keeps the goods under the paper tariff entry.

Gummed paper was treated as falling within Tariff Item 17(2), and the exemption notification for gummed paper supported that classification. Slitting the duty-paid paper into narrower strips or tapes was held to be only a change in physical dimensions and not manufacture, because no new commercially distinct article emerged. Tariff Item 60, covering adhesive tapes, could not apply merely because the paper had been slit, as that entry presupposes manufacture and was treated as residuary in character. The goods therefore remained classifiable under Tariff Item 17(2), not Tariff Item 60, with consequential relief.

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Issues: Whether gummed paper tapes obtained by slitting duty-paid gummed paper were classifiable under Tariff Item 17(2) of the Central Excise Tariff or under Tariff Item 60 as adhesive tapes, and whether the slitting process amounted to manufacture.

Analysis: Gummed paper was found to be treated paper falling within Tariff Item 17(2), and the exemption notification for gummed paper confirmed that position. The subsequent slitting of such paper into narrower strips or tapes was held to be only a change in physical dimensions and not a process bringing into existence a new substance. Since Tariff Item 60 covers adhesive tapes and presupposes manufacture, the product could not be shifted into that entry merely because it had been slit. The trade understanding, technical usage, and the residuary character of Item 60 also supported retention of the goods under Item 17(2).

Conclusion: The gummed paper tapes were held classifiable under Tariff Item 17(2) and not under Tariff Item 60, and the appeal succeeded with consequential relief.

Ratio Decidendi: Slitting of treated gummed paper into narrower tapes, without emergence of a new commercially distinct article, does not amount to manufacture, and such goods remain classifiable under the paper tariff entry rather than a residuary adhesive-tape entry.

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