Packing material exemption covers glassine and greaseproof paper used for packing goods, securing concessional sales tax treatment.

Glassine paper and greaseproof paper used for packing were treated as "packing material" under the Rajasthan sales tax notification because the notification extended concessional treatment to packing material, including brown paper and other paper adapted for use in packing goods. Since these goods were ordinarily used for packing purposes, they fell within the broad scope of the exemption entry. The Tribunal's narrower view that they could not qualify for the concessional rate was found inconsistent with the notification's proper scope. The papers were therefore taxable at the concessional rate of 3 per cent in favour of the assessee.

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Issues: Whether glassine paper and greaseproof paper used for packing purposes fall within the expression "packing material" under the relevant sales tax notification and are therefore taxable at the concessional rate of 3 per cent.

Analysis: The relevant notification issued under section 5 of the Rajasthan Sales Tax Act, 1954 granted a concessional rate for packing material, including brown paper and other paper adapted for use in packing goods. The goods in question were found to be ordinarily used for packing purposes. On that basis, they were treated as falling within the broad class of packing material. The Tribunal's view that they could not get the benefit of the concessional notification was held to be arbitrary and not in tune with the proper scope of the notification.

Conclusion: Glassine paper and greaseproof paper are packing material and are liable to tax at the concessional rate of 3 per cent, in favour of the assessee.

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