Concessional duty for metallised plastic films upheld where duty-paid inputs and the prescribed heading chain were established.

Metallised plastic films were treated as eligible for concessional duty where they were manufactured from duty-paid plastic materials through duty-paid plain plastic films, because the exemption notification required only that the final goods under Heading 39.20 be produced from duty-paid goods falling within Headings 39.01 to 39.15. The presence of an intermediate plain film stage did not defeat eligibility, as the notification did not insist on a single integrated manufacturing process. The Board's circular supported this interpretation and, being binding on the Department, prevented the Revenue from taking a contrary view. The concessional rate was therefore available.

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Issues: Whether metallised plastic films produced from duty-paid plain plastic films, which in turn were manufactured from duty-paid plastic materials, were eligible for concessional duty under the exemption notification.

Analysis: The notification granted concessional duty to goods classifiable under Heading 39.20 when produced out of duty-paid goods falling under Headings 39.01 to 39.15. The existence of bare plastic films at an intermediate stage did not alter the essential fact that the final metallised films were produced from duty-paid inputs. The notification did not require an integrated manufacturing process, and the Board's circular supported eligibility where the duty-paid chain from the specified headings could be established. Board circulars are binding on the Department, and the Revenue could not adopt a contrary position.

Conclusion: The metallised plastic films were held eligible for the concessional rate of duty under the notification, and the Revenue's challenge was rejected.

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