Packing of goods for sale excludes storage aids, so protective covers were not eligible for registration inclusion.

The phrase "packing of goods for sale" in section 8(3)(c) of the Central Sales Tax Act was read narrowly, requiring use as packing material for sale rather than mere protection or storage. Fumigation covers, tarpaulins, nylon ropes and patramats were found to be used only to cover stacks, prevent moisture and keep foodgrains above the ground, so they facilitated preservation and storage but were not packing materials for sale. The four items were therefore not covered by section 8(3)(c) and could not be included in the registration certificate.

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Issues: Whether fumigation covers, tarpaulins, nylon ropes and patramats could be specified in the registration certificate as materials intended for being used for the packing of goods for sale under section 8(3)(c) of the Central Sales Tax Act, 1956.

Analysis: The expression used by the statute is not packing simpliciter but packing of goods for sale. The materials in question were used to protect, preserve and store foodgrains by covering stacks, preventing moisture and keeping the goods above the ground. Such use facilitated storage and preservation, but did not amount to use as packing material in which the goods were sold. The distinction between goods that merely facilitate business or storage and goods actually intended for packing was treated as material, and the broader meaning suggested for the phrase was rejected.

Conclusion: The four goods were not covered by section 8(3)(c) and were not entitled to inclusion in the registration certificate.

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