Printed stationery classified as products of printing under Chapter 49, not paper goods under Chapter 48.

Printed money receipts and continuous computer stationery manufactured on job-work basis were treated as products of printing rather than goods of paper manufacture, so classification under Chapter 48 was rejected. The goods were separate printed sheets prepared for a specific customer and purpose, and the administrative clarification, together with the assessee's earlier classification history, supported Chapter 49. As the legal and factual foundation of the show-cause notice no longer survived, the Revenue's challenge to the appellate classification failed.

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Issues: Whether the finished products manufactured on job-work basis, namely printed money receipts / continuous computer stationery, were classifiable under Chapter 48 as urged by the Revenue or under Chapter 49 as claimed by the assessee.

Analysis: The impugned classification under Chapter 48 was found unsustainable in view of the administrative clarification and the nature of the goods. The goods were separate printed sheets used for a specified customer and purpose, and their character as a product of printing brought them within Chapter 49 rather than Chapter 48. The earlier appellate view in the assessee's own case also supported the same classification, and the foundation of the show-cause notice therefore no longer survived.

Conclusion: The goods were held to be classifiable under Chapter 49, and the Revenue's challenge to the appellate order failed.

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