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Issues: Whether unwaxed printed paper cut into sheets and reels according to customer requirements for use as wrappers in packaging was a product of the printing industry so as to qualify for exemption under Notification No. 63/82 dated 28-2-1982.
Analysis: The exemption claimed under the notification depended on whether the goods could properly be treated as a product of the printing industry. The controlling test applied was whether the material remained a packaging product despite printing on it. Goods intended for packaging, even if printed, do not cease to belong to the packaging industry merely because printing has been carried out on them.
Conclusion: The goods were not a product of the printing industry and the exemption under Notification No. 63/82 dated 28-2-1982 was not available. The Tribunal's view was reversed.
Ratio Decidendi: Material used for packaging does not become a product of the printing industry merely because it is printed; exemption notifications must be applied according to the essential character and use of the goods.