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Issues: Whether printed cartons classifiable under Tariff Item 68 were entitled to exemption under Notification No. 55/75 as products of the printing industry.
Analysis: The exemption notification was held to require strict construction, and the burden rested on the assessee to establish entitlement. Printed cartons were found to serve primarily as containers and to belong to the packaging industry. Printing was not treated as the culminating process of manufacture, because after printing further processes such as cutting, slitting and creasing were required to complete the cartons. The fact that printing formed a major cost component or that printed containers were considered in printing-design awards was held insufficient to bring the goods within the expression 'products of the printing industry'.
Conclusion: Printed cartons were not products of the printing industry and were not eligible for exemption under Notification No. 55/75; the assessee's claim failed.
Ratio Decidendi: An exemption notification must be strictly construed, and goods whose essential character is that of packaging articles do not become products of the printing industry merely because printing is an important or costly process in their manufacture.
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