Excise liability for value-added plastic film conversions persists despite tariff subheading similarity; Modvat credit allowed.

Conversion of duty-paid bare plastic films into lacquered, laminated or metallised films constitutes manufacture of a new product and is liable to excise duty even if the end product falls under the same tariff sub-heading; following withdrawal of the exemption for metallised films, this view is supported by Board advice, Law Ministry opinion and subsequent decisions. Chapter 39 being covered by the Modvat scheme, credit for duty paid on bare films may be applied against duty on the converted lacquered/laminated or metallised films.

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