Dismissing the appeal of the revenue the Court held that ; assessee having imported garments, cut them into smaller pieces and sold to different parties in form of rags, wipers or chindi which were used by buyers in manufacturing other items like blankets, pillows etc., waste so manufactured would not fall within ambit of expression ‘scrap’ as envisaged in clause (b) of Explanation to S. 206C. Accordingly not liable to collect tax at source .(AY .2009-10 to (AY. 2013-14)