Tribunal rules printing and slitting processes do not create new commodity

The Tribunal ruled in favor of the Appellants, stating that the printing and slitting processes of cork tipping base paper into printed cork tipping cigarette paper did not result in the creation of a new commodity. The Tribunal found no substantial change in the product after these processes, aligning with the decision in the Lakshmi Packaging (P) Ltd. case. As a result, the impugned orders were set aside, and the appeals were allowed based on the precedent established in the Lakshmi Packaging (P) Ltd. case.

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Issues involved: Whether the process of printing and slitting of cork tipping base paper into printed cork tipping cigarette paper (PCT) amounts to manufacture.

Comprehensive Details:

1. Arguments by Appellants:
- Appellants engage in printing and slitting of Cork Tipping Paper (CTP) on job work basis.
- Reference to Tribunal's decision in Lakshmi Packaging (P) Ltd. case where printing on duty paid paper was not considered manufacture.
- Dispute allegations of change in properties and uses of printed paper.
- Mention of ink used, purpose of printing, and certificates obtained to support their position.

2. Arguments by Revenue:
- Emphasis on printing and slitting as processes creating a new product with different characteristics.
- Citing decisions where similar processes were considered as manufacture.
- Highlighting increase in value of product after printing and slitting.
- Distinguishing present case from Lakshmi Packaging (P) Ltd. case based on substantial value addition.

3. Tribunal's Analysis:
- Tribunal considers whether a new commercial commodity emerges or the original commodity loses its identity.
- Appellants argue that printed paper does not change the character or use significantly.
- Reference to Lakshmi Packaging (P) Ltd. case where printing on paper was not deemed manufacture.
- Tribunal finds no substantial change in the product after printing and slitting, following the Lakshmi Packaging (P) Ltd. decision.
- Show cause notice issued to Lakshmi Packaging (P) Ltd. also supports the Tribunal's decision.

4. Conclusion:
- Tribunal rules in favor of the Appellants, stating that the processes undertaken do not result in a new commodity.
- Impugned orders are set aside, and appeals are allowed based on the decision in Lakshmi Packaging (P) Ltd. case.

This summary provides a detailed overview of the arguments presented by both parties, the legal analysis conducted by the Tribunal, and the final decision reached based on the precedent set by the Lakshmi Packaging (P) Ltd. case.

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