Bias cutting of cotton fabric was not manufacture of cotton fabrics; it was only a step in making electrical tapes.

Bias cutting of hand-bleached cotton fabric, followed by gumming, chemical soaking, drying and conversion into tapes, was treated as only one step in the manufacture of electrical tapes, not as manufacture of cotton fabrics. The process therefore did not bring the material within Tariff Item 19(1)(b), because the relevant commodity was the final electrical tape product falling under Tariff Item 68. On that basis, no further duty was chargeable under Tariff Item 19(1)(b).

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Issues: Whether the process of bias cutting of hand-bleached cotton fabric amounted to manufacture of cotton fabrics under Tariff Item 19(1)(b), or was merely a process undertaken in the manufacture of electrical tapes falling under Tariff Item 68.

Analysis: The fabrics were received in hand-bleached form and were thereafter cut in a bias shape, joined together by gumming, soaked in chemical compound, dried, and finally converted into tapes. On these facts, the bias cutting was found not to be a manufacturing process of cotton fabrics. It was only a step in the manufacture of the final product, namely electrical tapes. Since the process related to a commodity falling under Tariff Item 68, no further duty could be levied under Tariff Item 19(1)(b).

Conclusion: The process did not attract duty under Tariff Item 19(1)(b); the Revenue's appeal failed.

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