Packing material under CST law includes tin sheets meant for conversion into containers for saleable goods.

Section 8(3)(c) of the Central Sales Tax Act, 1956 was construed broadly to cover not only ready-made containers but also tin sheets and tin plates intended to be fabricated into containers for packing goods for sale. The expressions "container" and "packing" were treated as having their ordinary, wide meaning, extending to materials capable of becoming receptacles where the dealer's intention was to use them for saleable goods. On that interpretation, tin sheets and tin plates meant for conversion into tin containers for vegetable oil products qualified, and refusal to amend the registration certificate was based on an error of law.

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Issues: Whether tin sheets and tin plates intended to be converted into tin containers for filling vegetable oil products fell within the expression "containers or other materials intended for being used for the packing of goods for sale" under section 8(3)(c) of the Central Sales Tax Act, 1956, so as to justify amendment of the registration certificate.

Analysis: The expression in section 8(3)(c) was held not to be confined to ready-made containers or to materials used only as wrappers for solid goods. The words "container" and "packing" were not technical terms defined in the Act, and their ordinary meaning was wide enough to include receptacles and materials capable of being converted into receptacles for storing or transporting goods for sale. The decisive consideration was the dealer's intention to use the goods as packing material or as containers for saleable goods, even if some fabrication or alteration was required before such use.

Conclusion: Tin sheets and tin plates intended to be converted into tin containers for packing vegetable oil products were covered by section 8(3)(c) of the Central Sales Tax Act, 1956. The refusal to amend the registration certificate rested on an erroneous interpretation of law.

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