Printing determines commercial identity of aluminium labels, so they qualify as products of the printing industry for exemption.

Printed aluminium labels were treated as products of the printing industry because their commercial identity and use were created by the printing itself. The Court applied trade and common parlance, asking whether printing was merely incidental or the essential feature of the article. As the printed matter gave the labels their function and identity as labels, the substrate being aluminium did not defeat exemption. The labels therefore qualified for exemption under the relevant central excise notification, and the benefit could not be denied simply because the article was printed on a non-paper base.

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Issues: Whether printed aluminium labels manufactured by the assessee are "products of the printing industry" entitled to exemption under Notification No. 55/75-C.E. dated 1-3-1975 issued under Rule 8(1) of the Central Excise Rules, 1944.

Analysis: The decisive test was the nature of the product as understood in trade and common parlance and whether the printing was merely incidental or was the essential feature giving the article its commercial identity. The labels were printed on aluminium sheets for attachment to consumer appliances and, unlike a carton that remains a carton whether printed or plain, the printed matter itself communicated the product identity and served the function for which the labels were made. On those facts, the printing was not incidental but primary, and the printing industry brought the label into existence as a label.

Conclusion: The printed aluminium labels are products of the printing industry and qualify for the exemption under the Notification.

Ratio Decidendi: Where the commercial identity and use of an article are created by the printing itself, and the article is understood in trade and common parlance as a printed product of the printing industry, exemption cannot be denied merely because the substrate is non-paper or because some printing is involved on the material.

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