Labels and stickers qualify for SSI exemption where the notification's wording is broad enough to cover them.

Labels and stickers manufactured by the appellant were treated as falling within the broad scope of clause 4(e) of the exemption notification. The Tribunal held that no artificial distinction could be drawn between labels and stickers, and that the expression used in the notification was wide enough to cover them. On that basis, the denial of small scale industry exemption on the ground that the goods were not packing materials was unsustainable. Exemption under Notification No. 8/2003-CE was therefore available to the appellants, and the contrary view in the impugned order could not stand.

---

---

Issues: Whether labels and stickers manufactured by the appellant were eligible for small scale industry exemption under the relevant exemption notification.

Analysis: The Tribunal followed its earlier view that clause 4(e) of the exemption notification covered labels and stickers within its scope. It held that the expression was wide enough to include labels, and that no artificial distinction could be drawn between labels and stickers. On that reasoning, the denial of exemption on the footing that such goods were not packing materials was unsustainable.

Conclusion: The labels and stickers were eligible for exemption under Notification No. 8/2003-CE, and the contrary view taken in the impugned order could not be sustained.

Final Conclusion: The impugned order was set aside and the appeals were allowed, granting the exemption benefit to the appellants.

Ratio Decidendi: Labels and stickers falling within the broad description used in the exemption notification are entitled to SSI exemption, and a narrow distinction excluding them from the benefit is impermissible.

---