Tyre cord warp fabrics classification turns on tariff identity of the base fabric, not ingredient predominance.

Tyre cord warp sheets dipped in resorcinol solution were treated as fabrics for excise classification because tyre cord warp fabrics fall within the broad expression "all varieties of fabrics" in Item 22. The decisive point was that the dipping and drying process produced a commercially distinct product amounting to manufacture, while the predominance of ingredients was not controlling where the tariff entry covered impregnated or coated base fabrics. On that reasoning, the goods were classifiable under Tariff Item 22 rather than Tariff Item 16A(2), and the Revenue's classification view was upheld.

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Issues: Whether tyre cord warp sheets dipped in resorcinol solution were classifiable under Tariff Item 16A(2) of the erstwhile Central Excise Tariff as rubber products or under Item 22 as fabrics.

Analysis: The controlling principle was that tyre cord warp fabrics are fabrics within the wide expression "all varieties of fabrics" in Item 22. The Court relied on the settled position that tyre fabric is regarded as textile fabric and that the process of dipping and drying produced a commercially distinct product amounting to manufacture. It further held that predominance of ingredients was not decisive in the present classification dispute, since the relevant item covered impregnated or coated base fabrics.

Conclusion: The goods were held classifiable under Tariff Heading 22, not under Tariff Item 16A(2), and the classification adopted by the Revenue succeeded.

Ratio Decidendi: Tyre cord warp sheets retain the character of fabrics for excise classification, and where a tariff entry covers all varieties of fabrics including impregnated or coated fabrics, classification depends on the commercial and tariff identity of the base fabric rather than on the predominance of the added material.

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