Custom-printed labels and wrappers lose their character as packing paper and fall outside the sales tax entry.

Printed labels and wrappers made to customer specifications were held not to fall within entry 143 of the Andhra Pradesh General Sales Tax Act. The court treated the word "paper" as referring to the actual character of the goods after printing and cutting: paper that retains general utility for wrapping or packing goods may remain packing or wrapping paper, but material converted into labels or specially cut wrappers for particular goods loses that identity. On the same reasoning, such products also do not qualify as "all other kinds of paper and paper board" because they cease to be paper in the sense used in the entry.

---

---

Issues: Whether printed labels and wrappers prepared to customer specifications fall within entry 143 of the First Schedule to the Andhra Pradesh General Sales Tax Act as packing or wrapping paper, or as other paper and paper board.

Analysis: Entry 143 was construed with emphasis on the word "paper" and on the actual character of the goods after printing and cutting. Printed paper remains packing or wrapping paper when it retains a general utility for wrapping or packing goods, such as when it bears only a general design. But where paper is printed and cut so as to bring into existence labels or wrappers meant for particular goods and not for general wrapping use, it loses its identity as packing or wrapping paper. For the same reason, such goods also do not answer the description of "all other kinds of paper and paper board" because, once transformed into labelled or specially cut articles, they cease to be paper in the sense used in the entry.

Conclusion: The printed labels and wrappers did not fall within entry 143 and were not taxable as packing or wrapping paper or as other paper under that entry.

---