GSM-based classification of white cardboard denied exemption where the goods fell outside the paper notifications.

White cardboard of 300 GSM was treated as board, not paper, for exemption purposes because the governing notifications covered only writing paper or printing and writing paper. The test report and import documents identified the goods as white cardboard, and the cited precedent distinguished paper from board at grammages above 225 GSM. A Larger Bench ruling also limited the relevant printing and writing paper notification to goods not exceeding 180 GSM. On that basis, the goods fell outside the exemption and the Revenue's position prevailed.

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Issues: Whether white cardboard of 300 GSM was to be treated as paper or board for the purpose of exemption under the relevant notifications.

Analysis: The test report and import documents showed the goods as white cardboard with a grammage of 300 GSM. The applicable notifications granted benefit only to writing paper or printing and writing paper, and the governing precedent drew the line between paper and board at grammages above 225 GSM, while another Larger Bench held that the relevant notification for printing and writing paper applied only where the grammage did not exceed 180 GSM. On the record, the goods fell outside the scope of the exemption.

Conclusion: The goods were not eligible for the notification benefit and the appeal succeeded in favour of Revenue.

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