Printed cartons are classified by functional character, not printing activity, and remain dutiable packaging products.

Printed cartons are classified by their common parlance and functional character under taxing law, not by the extent of printing involved in manufacture. A carton remains a carton even if printed, cut, creased, folded or glued, because printing is incidental to its essential role as a container for packing goods. Substantial printing cost or specialised printing activity does not convert the finished article into a product of the printing industry. Only where printing itself is the culminating manufacturing process for the end product can the article be treated as such. On this reasoning, printed cartons were held to belong to the packaging industry and the exemption was unavailable.

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Issues: Whether printed cartons are products of the printing industry and therefore exempt from excise duty under the relevant exemption notification, or whether they remain products of the packaging industry and are dutiable.

Analysis: The controlling test for classification under taxing law is the meaning of the product in common parlance and by its functional character, not the extent of printing work involved or the place where manufacture occurs. The Court held that a carton remains a carton even if printed, cut, creased, folded, or glued, because printing is only incidental to its essential function as a container for packing goods. The fact that the process may involve substantial printing cost or specialised printing activity does not convert the finished carton into a product of the printing industry. The Court preferred the reasoning that only where printing itself constitutes the culminating process of manufacture for the end product can the article be treated as a printing industry product.

Conclusion: Printed cartons are products of the packaging industry and not products of the printing industry, so the exemption was not available; the impugned exemption claim failed.

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