Packing materials include polythene sacks for seedlings, making them liable to entry tax under the local goods tax entry.

High density polythene punched woven sacks used for growing, storing or carrying seedlings were treated as "packing materials" under entry 16-A of the Karnataka Tax on Entry of Goods into Local Areas for Consumption, Use or Sale Therein Act, 1979, attracting entry tax. The Court applied the ordinary and dictionary meaning of "packing materials" because the term was undefined, and held that packing depends on the nature of the article and the suitable mode of storage or carriage. The expression "and the like" was read as making the entry illustrative, while the specific exclusion of country-made earthen pots confirmed that containers used for seedlings could otherwise fall within the entry.

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Issues: Whether high density polythene punched woven sacks used for growing, storing or carrying seedlings fall within the expression "packing materials" under entry 16-A of the Karnataka Tax on Entry of Goods into Local Areas for Consumption, Use or Sale Therein Act, 1979 so as to attract entry tax.

Analysis: The expression "packing materials" was not defined in the Act and was therefore construed according to its ordinary and dictionary meaning. The Court held that packing depends on the nature of the article and the mode of packing suitable for it. In the case of seedlings, bags or similar containers are a practical means of storage, carriage and preservation, and punching holes in the sacks for drainage does not alter their essential character as bags. The use of the expression "and the like" in entry 16-A showed that the categories of packing materials were illustrative and not exhaustive. The exclusion of country-made earthen pots also indicated that the Legislature treated containers used for seedlings as capable of being packing materials, subject only to specific exclusions.

Conclusion: High density polythene punched woven sacks used for seedlings are packing materials within entry 16-A and are liable to entry tax. The writ petition was without merit.

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