Exhaustive sales-tax entry for packing material excluded bamboo crates before the statutory amendment.

The phrase "that is to say" in a sales-tax entry was treated as exhaustive, so only the goods expressly listed could fall within the packing-material classification under the M.P. General Sales Tax Act, 1958. After the 1 October 1978 amendment, the Legislature defined "packing material" by reference to the specified goods and added a power to notify additional items, confirming that unenumerated goods could not be included by implication. On that construction, bamboo crates, not being specifically named before the amendment, were outside the packing-material entry and were taxable under the residuary entry; the issue was answered for the Revenue.

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Issues: Whether bamboo crates were covered by the entry relating to goods used as containers and packing material under the M.P. General Sales Tax Act, 1958, prior to 1 October 1978.

Analysis: The expression "that is to say" in the relevant entry was treated as limiting the scope of the listed goods, making the entry exhaustive rather than illustrative. After the amendment with effect from 1 October 1978, the Legislature introduced a definition of "packing material" linked to the goods specified in the entry and also added a power to notify other goods. On that reasoning, goods not specifically enumerated in the entry could not be treated as packing material by implication. For the period prior to 1 October 1978, bamboo crates were not specified in the entry and therefore could not be brought within it merely because they were used for packing.

Conclusion: Bamboo crates were not covered by the packing-material entry prior to 1 October 1978 and fell under the residuary entry; the question was answered in favour of the Revenue.

Ratio Decidendi: Where a sales-tax entry uses the words "that is to say", the enumerated goods constitute an exhaustive class, and items not specifically included cannot be treated as covered except by express notification or legislative amendment.

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