Printing transactions turn on the parties' intention and may be treated as sale of a finished product rather than a works contract.

The characterization of printing turnover depends on the parties' intention viewed as a whole and on the nature of the bargain. Where the customer is found to have contracted for and paid for a finished product, separate bill entries for labour and materials may be treated as an artificial apportionment rather than a genuine segregation of a works contract. On the facts recorded, the Tribunal's finding that the transaction was for a completed commodity was supported by the evidence, so the suggested split between labour charges and material cost was not accepted.

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Issues: Whether the turnover from printing work represented a works contract with separable labour charges and material cost, or an outright sale of a finished commodity.

Analysis: The decisive test was the intention of the parties viewed as a whole. The Tribunal's finding that the customer wanted and paid for a finished product was supported by the record, and the separate entries in the bills were treated as an artificial apportionment. In such transactions, the characterization depends on the facts and the nature of the bargain, and the suggested dissection into labour and materials was not warranted on the facts found.

Conclusion: The transaction was held to be a sale of a finished product and not a works contract with separable labour and materials; the assessee's challenge failed.

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