Tariff classification of plain composite containers turns on substance, not pasted labels, and printed-container headings do not apply.

Mere pasted printed labels on otherwise plain composite containers do not make them printed cartons, boxes, containers or cases for tariff classification. The applicable tariff entries before 1-3-1988 covered printed containers under sub-headings 4818.12 and 4818.13, and after reclassification the corresponding entry was 4819.12, but the disputed goods remained outside those printed-container entries because their essential character was plain composite packaging. Classification therefore had to follow the substantive tariff description applicable to the goods, and the assessee's other-entry classification was accepted.

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Issues: Whether plain composite containers pasted with printed labels were classifiable under Heading 48.18/48.19 as printed cartons, boxes, containers or cases, or under the residuary entries claimed by the Revenue.

Analysis: The relevant tariff structure showed that, prior to 1-3-1988, printed cartons, boxes, containers and cases were specifically covered under sub-headings 4818.12 and 4818.13, while after reclassification from 1-3-1988 the corresponding entry became 4819.12. The containers in dispute were plain composite containers on which printed labels were merely pasted, and that did not make them printed containers within the tariff entries. The prior conflicting decisions were resolved by applying the reasoning that the later view correctly treated such composite containers as falling outside the printed-container entries and within the other-entry classification. Support was also drawn from earlier decisions on similar composite packing containers and from trade notice-based understanding of the classification position.

Conclusion: The composite containers pasted with printed labels were not classifiable as printed containers under sub-heading 4818.12/4818.13 or 4819.12, and the assessee's classification under the other relevant tariff entries was accepted.

Final Conclusion: The classification dispute was resolved in favour of the assessee, the contrary order was set aside, and the appeal was allowed with consequential relief.

Ratio Decidendi: Mere pasted printed labels on otherwise plain composite containers do not make the goods printed containers for tariff classification; classification must follow the substantive tariff description applicable to the goods.

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