9911796707
TMI Blog1998 (10) TMI 216X X X X Extracts X X X X X X X X Extracts X X X X ..... fication 49/87-C.E., dated 1-3-1987. 1.3 On the other hand, lower authorities have classified PSLS paper under Tariff sub-heading 4811.20 as Gummed or adhesive paper , and thermal paper under sub-heading 4810.10 as paper of a kind used for writing, printing or other graphic purposes . 2.1 Test report of the sample of PSLS, paper reads as follows :- The sample is a white sheet of paper of width 16.5 cm. coated on one side with adhesive based on acrylic resin, the coated side being backed with easily separable grassproof/glassine type of pale yellow coloured house printed paper. The furnish consists essentially of chemical pulp of wood. GSM of white paper (adhesive free basis) and the yellow backing paper are 84.4 and 79.7 respective ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... urface the label is designed for. The adhesive with some chemicals are coated on a paper surface. This system normally requires a release sheet which covers the adhesive until the label is ready to be fastened in place. At that time, the release sheet is removed and adhesive surface of the label is exposed. When the label is mated to the surface, the pressure sensitive mass forms an instant bond with the surface. PSLS is the combination of two components - backing and adhesive. However, the fastening role of the adhesive is secondary to the informative or decorative purposes of the label as the printed paper carries the message while adhesive keeps the label in place. 5.2 On the other hand, it is contended by the appellants that gummed or ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... of a kind used for writing, printing and other graphic purposes. It is classifiable under sub-heading 4810.10 being more specific while such sub-heading 4811.90 is more general. But this has been extended the benefit of exemption under Notification 49/87-C.E., dated 1-3-1987. Learned JDR has reiterated the aforesaid findings and has also advanced another classification under Tariff sub-heading 4823.11. 7.1 We have carefully considered the pleas advanced from both sides. In order to appreciate the rival contentions, we reproduce Heading 48.10 and sub-heading 4810.10, Heading 4811 and sub-headings 4811.20 and 4811.90 and Heading 4823 and sub-heading 4823.11 :- Heading No. Sub-head- ing No. Description of goods ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... orne out by any evidence. Test report clearly indicates that it is coated with an adhesive. Release paper backing the adhesive is only for protecting adhesive till the PSLS paper is used. Tariff sub-heading 4811.20 does not at all refer to the type of adhesive - whether water soluble or not. We are, therefore, of the view that classification under Tariff sub-heading 4811.20 of PSLS paper has been correctly made by the lower authorities being the most specific heading and sub-heading. Sub-heading 4823.11 advanced by Shri S.N. Ghosh, learned JDR, as an alternative classification need not be considered. 7.3 As regards classification of thermal paper, appellant s case appears to be on a basis so under than that of the Revenue. It is a coated ..... X X X X Extracts X X X X X X X X Extracts X X X X
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