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Issues: Whether printed labels of cloth, aluminium foil, film and paper were "products of the printing industry" entitled to exemption under the relevant excise notification.
Analysis: The exemption covered all products of the printing industry. The decisive consideration was whether the printing on the labels was merely incidental to their use or whether printing was the primary function giving the labels their utility. Applying the earlier decision that printed labels serve a definite purpose by communicating product information and would be of no useful purpose without printing, the same reasoning was held applicable to the labels involved here.
Conclusion: The labels were held to be products of the printing industry and entitled to exemption. The appeal concerning that dispute was allowed.
Final Conclusion: The common issue was resolved in favour of the assessee for one appeal, while the connected appeal was disposed of in accordance with the same precedent.
Ratio Decidendi: Printed labels are products of the printing industry where printing is the primary source of their utility and not merely incidental to their use.