(1) THE question in this case is whether the printed cartons manufactured by the respondents can be described as product of Printing Industry. The printed cartons manufactured by the respondent have been treated by the tribunal as products of Printing Industry. The question was examined by this court in the case of Rollatainers Ltd. v. Union of India, 1994 (72 E.L.T. 793 (S.C.), where it was categorically held that:

"WHAT is exempt under the Notification is the Product of the Printing Industry. The product in this case is the carton. The Printing Industry by itself cannot bring the carton into existence. Any amount of fancy printing on a card-board would not make it a carton. In the process of manufacturing the printed cartons, the card-board has to be cut, printed, creased and given the shape of a carton by using paste or gum. Simply because there are expensive prints on the carton such a printed carton would not become the product of the Printing Industry. It shall remain the product of the Packaging Industry."

(2)

ON behalf of the respondent it has been argued that the principle laid down in that case has to be limited to the facts of that case. There is a