'Cellophane' is made from wood pulp, cotton seed, etc. It is a wrapping material produced from viscose which is the gum substance extracted from wood pulp or from any other pulp as also from bam­boo pulp. The petitioner's manufacture is produced from viscose which is extracted from bamboo pulp. The High Court has pointed out that item 35 of the First Schedule of the Central Excise and Salt Act (1 of 1944) does not propose to tax either the wood pulp or the bamboo pulp or the viscose produced from any of the two. It proposes to tax the product made out of the viscose which is a flexible cellulose film widely used for packa­ging. The process of making 'Dilphane' and 'Cellophane' is the same. It, therefore, will not make any difference whether the viscose is ob­tained from bamboo pulp or from wood pulp or from cotton seed and consequently, there­fore, there will be no difference between 'Dil­phane' and 'Cellophane' both of which are soft cellulose films used as packaging materials. (Karnaphuli Rayon and Chemical Ltd. Vs. Collector of Central Excise & Land Customs, East Zone, Chitttagong & another, 1975, 4 CLC (AD) [951])

See Dilphane from CLC's Judicial Dictionary.