Embossing treated as printing for customs exemption, so imported plastic bags qualified for the notification benefit.

Embossing on imported plastic bags was treated as printing for purposes of the customs exemption notification. Note 2 to Chapter 49 of the First Schedule to the Customs Tariff Act, 1975 expressly includes embossing within printing, and that tariff meaning was applied consistently to the notification. The notification was construed according to its plain wording, and the goods therefore answered the description of printed bags. The exemption benefit was available to the assessee.

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Issues: Whether embossing on imported plastic bags could be treated as printing for the purpose of availing the benefit of the customs exemption notification.

Analysis: Note 2 to Chapter 49 of the First Schedule to the Customs Tariff Act, 1975 expressly includes embossing within the meaning of printing. The same understanding is reflected in the dictionary meaning relied upon. When an exemption notification uses language consistent with the tariff context, the interpretative meaning recognised for the tariff entry can be applied to the notification. The notification had to be given effect according to its plain wording, and the goods answered the description of printed bags for the exemption.

Conclusion: Embossing was held to fall within printing, and the assessee was entitled to the notification benefit.

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