Hand Printing Exemption Survives Ancillary Appliances Where Actual Printing Is Not Machine-Based

Exemption for processed man-made fabrics turned on whether the printing process was ordinarily conducted with the aid of machines. The notification was to be strictly construed, and the explanation limited "processed" to machine-aided processes. On the facts, the activity was hand printing; the steam-heated tables were only drying arrangements, the baby boiler was merely for heating water, and the electrically operated stirrer was used only to mix colours and chemicals for dye preparation. Those ancillary appliances did not make the actual printing process machine-based. The exemption therefore remained available and could not be denied on the ground of machine aid.

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Issues: Whether the appellants were entitled to the benefit of the exemption notification for processed man-made fabrics, and whether the use of a baby boiler, steam-heated tables and an electrically operated stirrer amounted to a process ordinarily conducted with the aid of machines so as to deny the exemption.

Analysis: The notification exempted processed man-made fabrics, and its explanation confined the expression "processed" to a process ordinarily conducted with the aid of machines, whether operated with or without power or steam. The exemption had therefore to be strictly construed. On the facts, the printing activity was found to be hand printing, and the tables used for drying were not treated as machines merely because they were specially arranged with steam pipes. The baby boiler was regarded as an appliance for heating water, not a machine for printing. The stirrer was used only for mixing colours and chemicals to prepare the dye solution, and that activity was not equated with the process of printing or with a process incidental or ancillary to printing.

Conclusion: The appellants were entitled to the exemption and the goods were not liable to be denied the notification benefit on the ground that the process was conducted with the aid of machines.

Ratio Decidendi: For an exemption limited to processes ordinarily conducted with the aid of machines, hand printing does not lose the benefit merely because ancillary appliances such as a boiler, heated table or stirrer are used for preparation or drying, unless the actual process of printing itself is machine-based.

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