Exemption for printed cartons turns on parent paperboard material, not later printing, under the notification.

Printed cartons made from corrugated paperboard remained eligible for exemption under Notification No. 59/88 because the relevant factor was the parent paperboard material used to make the cartons, not the later printing process. The Tribunal applied earlier decisions and held that the exemption for printed cartons, boxes and containers made of paper or paperboard falling within the specified tariff headings would be defeated if printing alone denied relief. On that interpretation, cartons manufactured from qualifying paperboard did not lose exemption merely because they were printed after manufacture, and the departmental challenge failed.

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Issues: Whether cartons manufactured from corrugated paperboard and printed after manufacture were eligible for exemption under Notification No. 59/88 on the basis that the parent material fell under the specified tariff heading.

Analysis: The notification exempted printed cartons, boxes and containers made out of paper or paperboards falling within the specified headings. The dispute turned on whether the material used before printing should control eligibility or whether printing changed the classification so as to defeat the exemption. The Tribunal followed earlier decisions holding that, for the purpose of the notification, the relevant consideration is the parent material from which the cartons are made, not the later printing process. On that approach, denying the exemption merely because the board becomes printed would make the notification ineffective, since printed cartons are ordinarily produced by printing the board first and then converting it into cartons.

Conclusion: The cartons were entitled to the exemption, and the departmental appeal failed.

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