Packing paper used with exempt book printing paper qualifies for the same exemption and is not separately dutiable.

Mill wrapper paper used to pack exempt book printing paper was treated as part of the goods marketed in wrapped condition, so it was eligible for the same exemption. Notification No. 217/86 covered goods manufactured in a factory and used within the factory in the manufacture of final products, and Notification No. 61/88 exempted book printing paper meeting the prescribed conditions. Because the book printing paper was already accepted as exempt and the wrapper paper functioned only as packing material integral to its sale, the wrapper paper could not be separately denied exemption or subjected to duty.

---

---

Issues: Whether mill wrapper paper used for packing exempt book printing paper was eligible for exemption under the relevant notifications, and whether duty could be demanded on such wrapper paper.

Analysis: Notification No. 217/86 exempted specified goods manufactured in a factory and used within the factory in the manufacture of final products specified in the notification. Notification No. 61/88 granted exemption to book printing paper satisfying the prescribed conditions. The book printing paper manufactured by the appellants was already accepted as exempt. The dispute concerned only the wrapper paper used for packing the paper in reams or reels. Following the principle that paper is marketed in wrapped or packed condition and that wrapping paper used for such wrapping is to be treated as a raw material or component part of the paper so packed, the wrapper paper could not be treated separately for the purpose of denying exemption.

Conclusion: Mill wrapper paper used for packing exempt book printing paper was also entitled to exemption, and no duty was demandable on the wrapper paper.

Ratio Decidendi: Where wrapping paper is used as an integral component in packing paper, it forms part of the paper marketed in wrapped condition and is eligible for the same exemption as the packed paper.

---