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Issues: Whether the sale of packing paper to a certified village-industry institution qualified for exemption as goods connected with the manufacture of soap under Notification No. 7037 dated January 31, 1985, and whether the seller could be denied exemption because the purchaser allegedly used the goods only as packing material.
Analysis: The relevant notification exempted purchases of goods connected with the manufacture of products of village industries, subject to a certificate duly countersigned in the prescribed manner. The seller had furnished the requisite certificate and the genuineness of that certificate was not disputed. The expression "connected with" was construed broadly in light of the object of the notification, namely to promote village industries and make their products marketable. Packing paper was treated as an item intimately linked with the product, since proper packing contributes to saleability, preservation, and commercial viability of soap. The seller could not be penalised for any misuse, if at all, by the purchaser, when the seller had complied with the notification conditions.
Conclusion: The sale of packing paper was exempt, and the disallowance of exemption by the authorities below was not sustainable.
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