ORDER

1. The only question which arises for consideration in this appeal is whether the process known as "soap treatment" whereunder Grey Cotton Duck/Canvas is treated with soap, colour and water in a soaping machine and the processed fabric is used in different shops of the tyre factory of the appellant for wrapping rubberised cloth layer by layer so that the same do not get pasted or glued together, amounts to a manufacturing process. It has been so held by the Central Government in revision by its order dated 27-12-1976. This appeal has been filed against the said order.

2. We have heard Dr Sankar Ghosh, learned Senior Counsel appearing for the appellant, and Mr Joseph Vellapally, learned Senior Counsel appearing for the respondent.

3. The process has been described in the impugned order in the following words :

"For processing on soap treatment the party use soaps/soap flakes which are diluted in plain water in a tank. This solution is transferred to a Soaping Machine operated by power where different colours are added. The fabrics are then dipped in the solution which is heated with steam. After the colouring treatment and soap impregnation the wet fabrics are dried up with the ai