SSI exemption and label classification clarified, supporting waiver of pre-deposit despite branded-packaging objections.

An amended SSI exemption notification clarified that packing material includes labels of all kinds, which supported the applicant's prima facie claim that printed labels bearing another's name could still fall within the exemption. The demand had proceeded on the basis that such labels were branded and outside SSI benefit, but the clarification weakened that objection at the pre-deposit stage. The plea that the amendment operated prospectively did not defeat interim relief, and waiver of pre-deposit was granted with stay of recovery.

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Issues: Whether the applicant was entitled to waiver of pre-deposit in view of the amended SSI exemption notification clarifying that packing material includes labels of all kinds.

Analysis: The demand was raised on the premise that printed labels bearing another's name were branded and outside the SSI exemption. A subsequent amendment to the exemption notification inserted an explanation clarifying that packing material includes labels of all kinds. On a prima facie view, this clarification supported the applicant's claim for exemption, and the plea that the amendment was prospective did not displace the case for interim relief at the stage of pre-deposit.

Conclusion: The applicant was entitled to waiver of pre-deposit and stay of recovery.

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