Classification of printed wrappers for razor blades governed by tariff entry-specific clarification, with linked exemption treated as available.

Printed wrappers for safety razor blades were discussed as being classifiable under sub-heading 4823.19 of the Central Excise Tariff, rather than sub-heading 4823.90, because a Board clarification treated printed wrappers cut to size as covered by the specific tariff entry. That clarification also recognised eligibility for exemption as printed paper under Notification No. 49/87-C.E. The commentary states that the classification dispute was governed by the departmental clarification, and the competing view under sub-heading 4823.90 was not accepted, leading to acceptance of the Revenue's classification and rejection of the assessee's challenge.

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Issues: Whether printed wrappers for safety razor blades were classifiable under sub-heading 4823.19 of the Schedule to the Central Excise Tariff Act, 1985 or under sub-heading 4823.90, and whether they were entitled to exemption under Notification No. 49/87-C.E. dated 1-3-1987.

Analysis: The Board's clarification treated printed wrappers cut to size as falling under sub-heading 4823.19 and recognised their eligibility for exemption as printed paper under Notification No. 49/87-C.E. The classification dispute was therefore governed by that clarification, and the competing view that the goods fell under sub-heading 4823.90 was not accepted.

Conclusion: The printed wrappers were held to be correctly classifiable under sub-heading 4823.19, with the result that the Revenue's appeal succeeded and the assessee's appeal failed.

Final Conclusion: The common order was modified by accepting the Revenue's classification and rejecting the assessee's challenge to the impugned classification.

Ratio Decidendi: Printed wrappers cut to size are to be classified according to the specific tariff entry covering them, and a binding departmental clarification on such classification governs the availability of the linked exemption.

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