Inclusive meaning of printing in exemption law brings embossed bags within printed bags and secures notification benefit.

Embossed plastic bags were treated as falling within the expression "printed bags" in Notification No. 21/2002 because Note 2 to Chapter 49 of the Customs Tariff Act expressly includes embossing within "printing". That inclusive tariff meaning was applied while construing the exemption notification, since the notification had to be read on its own language and consistently with the incorporated statutory definition. On that basis, embossing could not be excluded from the scope of printed bags, and the exemption was available. The denial of exemption was therefore unsustainable, and the assessee received the consequential benefit.

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Issues: Whether embossed plastic bags fell within the expression "printed bags" in Notification No. 21/2002 so as to qualify for exemption.

Analysis: Note 2 to Chapter 49 of the First Schedule to the Customs Tariff Act, 1975 expressly treated "printing" as including embossing. The same meaning was supported by the dictionary meaning relied upon. Since the notification was to be construed according to its own language, and the exemption covered printed bags, the interpretation of the tariff note was applicable while reading the notification. On that basis, embossing could not be excluded from the expression printed bags for the purpose of the exemption.

Conclusion: The embossed bags were entitled to the benefit of the notification and the denial of exemption was unsustainable.

Final Conclusion: The appeal succeeded and the assessee obtained the consequential benefit arising from the exemption.

Ratio Decidendi: Where the statutory context defines or includes a process within a term used in an exemption notification, that inclusive meaning governs the notification if its language is plain and the benefit cannot be denied by adopting a narrower construction inconsistent with the incorporated tariff meaning.

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