Handmade marble stone articles qualify as handicrafts when artistic features and handwork predominate, attracting the lower tax rate.

Marble stone articles made predominantly by hand, with artistic features such as ornamentation or inlay work, were treated as handicrafts rather than ordinary stone articles. Applying the handicraft test, the court noted that the Tribunal had not examined the products' characteristics and relied too broadly on the general stone-article entry. The materials on record, including departmental clarification on handmade stone works, sculptures, stone reliefs and stone inlay work, supported classification as handicrafts. As a result, the goods fell under the handicraft entry and were taxable at the lower rate, not under the higher-rate entry for stone articles.

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Issues: Whether the marble stone articles manufactured and sold by the assessee were handicrafts taxable at the lower rate under Entry 22-A of Part C of the First Schedule, or stone articles taxable at the higher rate under Entry 13 of Part E of the First Schedule.

Analysis: The governing test for handicrafts is whether the article is predominantly made by hand and bears artistic features such as ornamentation or inlay work lending it visual appeal. The Tribunal had treated the goods as stone articles without examining their characteristics. The materials on record, along with the departmental clarification on handmade stone works, sculptures, stone reliefs and stone inlay work, showed that the products were handmade and fell within the concept of handicrafts. Once the goods satisfied the handicraft test, they could not be classified under the general entry for stone articles.

Conclusion: The marble stone articles were handicrafts and were liable to be assessed at 8% under Entry 22-A of Part C of the First Schedule, not at 16% under Entry 13 of Part E of the First Schedule.

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