Composite sale in containers includes packing value in taxable turnover; separate taxation of packing materials was not established.

Packing charges and the value of containers used in liquor sales were includible in taxable turnover where the bargain was for goods sold in composite container-based transactions. The claim for deduction under rule 6(cc) failed because the sale was not of packing material as a separate element; the turnover had to cover both contents and containers. A separate levy on packing materials at a different rate also was not available, since the materials were not shown to be classified in the Schedule or dealt with as independent commodities. Invoices describing the goods as cases or crates further supported inclusion in turnover.

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Issues: Whether packing charges and the value of packing materials used in the sale of liquor in containers were deductible from taxable turnover, and whether packing materials could be treated as an independent commodity taxable separately at a different rate.

Analysis: The assessment related to liquor sold in containers such as glass bottles and wooden crates. The claim for deduction of packing charges under rule 6(cc) failed because the sale bargain was for goods in containers, making the transaction a composite one. The turnover therefore had to include both contents and containers. The plea that packing materials were separately taxable as an independent commodity also failed, because the Supreme Court principles relied on required the packing materials to be separately classified in the Schedule, which was not shown here. The invoices also described the goods in terms of cases or crates, supporting the view that the packing material was not dealt with as a separate commodity.

Conclusion: The packing charges and packing materials were rightly included in taxable turnover and could not be excluded or separately taxed on the facts of the case.

Ratio Decidendi: Where the bargain is for goods sold in containers as a composite transaction, and the packing material is not separately classified and sold as an independent commodity, its value forms part of the taxable turnover.

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