Dominant character test applied to printed labels, which were treated as a works contract rather than an inter-State sale.

Printed labels made to customer specifications were characterised by their real nature and the parties' intention, not by assumptions about materials or general marketability. Because the labels were prepared for specific customers and were not shown to be independently saleable as ordinary goods, the transaction was treated as execution of work rather than a sale of goods under the Central Sales Tax framework. The court accepted the concurrent factual and legal finding in favour of the assessee and declined interference.

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Issues: Whether the printed labels supplied according to customers' specifications constituted a works contract or an outright inter-State sale under the Central Sales Tax regime.

Analysis: The transaction had to be characterised on its real nature and the intention of the parties. The labels were printed for particular customers and were not independently saleable in the open market in the way ordinary goods are. The assessing authority proceeded on assumptions about marketability and the primary use of materials, without evidence to show that the supply was a sale of goods rather than execution of work. The reasoning in the cited authorities was examined, but the facts here were held to fall within the principle that the nature of the contract must be determined from the transaction as a whole.

Conclusion: The supply of printed labels was held to be a works contract and not an outright inter-State sale.

Final Conclusion: The revenue failed to dislodge the concurrent factual and legal finding in favour of the assessee, and no interference was warranted.

Ratio Decidendi: A printed-item transaction must be classified according to its dominant character and the intention of the parties, and where the printed materials are prepared for a specific customer and are not shown to be independently marketable as goods, the transaction is a works contract rather than a sale.

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