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Issues: Classification of hanging cards for central excise purposes, and whether they were classifiable as articles of paper under Heading 48.23 or as products of the printing industry under Chapter 49.
Analysis: The product consisted of cards bearing printed advertising matter and samples of the advertised article. The determining test was the dominant characteristic and main purpose of the goods. The printing was not merely incidental but was intended to advertise and display the product, making the advertising function the primary feature. The fact that the cards were made of paper or paper board did not by itself justify classification under the residuary paper heading, and the presence of attachable samples did not change the essential nature of the goods. The earlier treatment of the product as a product of printing industry and the grant of exemption under Notification No. 234/82 supported the same classification approach.
Conclusion: The hanging cards were correctly classifiable under Chapter 49 and not under Heading 48.23.