Contract work exemption turns on the nature of job-work, not on who purchased the raw materials.

Exemption under Notification S.R.O. No. 364/88 depends on whether the turnover arises from contract work or job-work, not on whether the customer supplied the raw materials or the assessee purchased them itself. The authorities' view that self-purchased materials disqualified the claim was rejected as legally incorrect. However, the record was found insufficient on proof of the work orders and contract documents, so the assessee was to be given an opportunity to produce evidence and the matter was remitted for fresh consideration on the contract nature of the work.

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Issues: Whether the assessee was entitled to exemption under Notification S.R.O. No. 364/88 in respect of turnover from printing job-work, and whether the fact that the assessee itself purchased raw materials disentitled it from the benefit.

Analysis: The notification was held to grant exemption to turnover representing contract work. The decisive question was whether the turnover arose from execution of job-work under a contract with customers. The authorities below proceeded on the erroneous premise that exemption was unavailable unless the raw materials were supplied by the customers or purchased in their names. That understanding was rejected, as the source of the raw materials was held to be irrelevant. At the same time, the record was found deficient on the factual aspect of proof of work orders and contract documents, and the assessee was considered entitled to an opportunity to produce the necessary materials.

Conclusion: The assessee was not denied exemption on the ground that it purchased raw materials itself, but the matter was remitted to the assessing authority for fresh consideration and for production of evidence regarding the contract nature of the work.

Ratio Decidendi: For exemption under Notification S.R.O. No. 364/88, the relevant test is whether the turnover represents contract work or job-work, and not whether the raw materials were supplied by the customer or purchased by the assessee.

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