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(3) Polyurethane foam.

(4) Articles made of Polyurethane foam.

Explanation I.-For the purpose of sub-item (2), "Plastics" means the various artificial or synthetic resins or plastic materials or cellulose esters and others included in sub-item (1).

Explanation II.-This item does not include electrical insulators or electrical insulating fittings or parts of such insulalors or insulating fittings.

12. As the heading of the item indicates, it provides for payment of excise duty on manufacture of artificial or synthetic resins and plastic materials and cellulose esters and ethers as also on the manufacture of articles made therefrom. Clauses (i), (ii) and (iii) of sub-item (1) describe artificial or synthetic resins and plastic materials, and cellulose esters and ethers, which when manufactured in any form whether solid, liquid or pasty, or as powder, granules or flakes or in the form of moulding powder would attract payment of excise and special excise duty mentioned therein. It is significant to note that the material mentioned in sub-item (1) is manufactured not for the purpose of being directly put to use in the same condition in which it is manufactured. The object with which such material is manufactured is to use it as raw material in manufacturing various articles which are generally sold in the market for being used as such. What sub- item (2) read in the light of Explanation I means is that manufacture of articles made of various articles or synthetic resins or plastic materials or cellulose esters and ethers mentioned in sub-item No. (1) would also attract payment of duty. The scheme underlying the tariff item makes a clear distinction between the plastic material described in sub-item No. (1) and the articles made therefrom. Sub-item No. (2) covers only those articles which after being manufactured, are meant to be sold for being used as such, but then as it was intended to levy duty on tubes, rods, sheets, foils, sticks, other rectangular or profile shapes etc, mentioned in sub-item (2) manufactured from the material mentioned in sub-item (1) which are generally not meant to be used as such but are meant to be converted into some other article. Accordingly it has, in sub-item (2) been provided that articles made of plastics, all sorts, would include the aforementioned items as well and that manufacture of such item would also attract payment of excise duty. Likewise, sub-item (2) provides for payment of excise duty on manufacture of polyurethane foam and sub-item (4) provides for payment of excise duty on manufacture of articles made of such foam. The scheme underlying tariff item 15A thus envisages that whereas the manufacture of material [sub- item Nos. (1) and (3)] as also the articles manufactured from such material [sub-item Nos. (2) and (4)] attract payment of excise duty, manufacture of a commercial articles by using the articles covered by sub-item Nos. (2) and (4) do not attract excise duty under this item. Of course as has been clearly mentioned in this item where there is any specific entry dealing with a particular article then notwithstanding that such article is made of material mentioned in sub-item No. (I) it would still not attract duty under sub-item No. (2) and that the duty payable in respect thereof will be governed by the specific article.