Manufacture of synthetic tops from fibre waste supports excisability and classification under Tariff Item 18.

Synthetic tops made from synthetic fibre waste and yarn waste were treated as a distinct excisable commodity because the process involved sorting, cutting, carding, garnetting and combing, not merely opening fibres for spinning. Those operations converted the waste into an intermediate product used in the manufacture of worsted yarn and traded as such, supporting manufacture and excisability. On that basis, the goods were held classifiable under Tariff Item 18 of the Central Excise Tariff, and the contention that the process did not amount to manufacture was rejected.

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Issues: Whether synthetic tops produced from synthetic fibre waste and yarn waste, after sorting, cutting, carding, garnetting and combing, amounted to a distinct excisable product classifiable under Tariff Item 18 of the Central Excise Tariff.

Analysis: The processes undertaken were not confined to garnetting alone but included sorting, cutting into smaller lengths, carding, orientation of fibres and combing. These steps went beyond a mere opening-up of fibres incidental to spinning and resulted in conversion of the waste into a different commodity. The tops were an intermediate product used for making worsted yarn and were traded as such, which supported the finding of excisability and classification under the relevant tariff item.

Conclusion: The synthetic tops were correctly classified under Tariff Item 18 and the appellant's contention that the processes did not amount to manufacture was rejected.

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