Packing material taxability follows the packed goods when no separate charge is made, limiting reassessment power.

Packing material sold with salt in plastic bags was treated as part of the goods packed, because Explanation-I to Section 4(2) of the Rajasthan Sales Tax Act and the 6 March 1978 notification indicated that, where no separate charge is made, the tax treatment follows the packed goods. As salt itself was not subject to sales tax, a separate levy on the packing material was not sustainable. The text also notes the Board's view that, after an assessment under Section 29, the Assessing Authority could not simply shift to reassessment under Section 30, which further supported the assessee's position.

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Issues: Whether packing material used for selling salt in plastic bags was separately taxable and whether the Assessing Authority could invoke reassessment despite the earlier self-assessment.

Analysis: The assessee sold salt packed in plastic bags. The Court relied on Explanation-I to Section 4(2) of the Rajasthan Sales Tax Act and the notification dated 6.3.1978, which together indicated that where packing material is sold along with goods and is not separately charged, the tax treatment follows the goods packed therein. Since salt itself was not subjected to sales tax, the packing material used for salt could not be subjected to a separate levy on the same footing. The Court also noted the Board's view that, once assessment had been made under Section 29, the Assessing Authority could not simply change course and reassess under Section 30, and stated that this reasoning also supported the assessee's case.

Conclusion: The tax and allied levy on the packing material were not sustainable and no question of law arose for interference.

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