Packing materials excluded from entry tax exemptions as raw materials, component parts, or inputs under the statutory scheme.

Packing materials used for tea were held not to fall within raw materials, component parts or inputs under the Karnataka Tax on Entry of Goods Act, 1979 or the related notifications. The Court treated the Act's definition of goods as exhaustive and noted that the statutory scheme separately classifies packing materials from raw materials, component parts and inputs. The exemption notification and the rate notification were read consistently with that scheme, so they could not be expanded to include packing materials. Explanation II to the 1998 notification did not alter that result, and provisions from sales tax, excise law, or the Tea Marketing Control Order could not be used to enlarge the entry tax exemption.

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Issues: Whether packing materials used for tea could be treated as raw materials, component parts or inputs under the Karnataka Tax on Entry of Goods Act, 1979 and the notifications issued thereunder so as to qualify for exemption or the concessional rate of entry tax.

Analysis: The definition of goods under the Entry Tax Act is exhaustive and does not import the marketability requirement relevant to excise law. The Act and the relevant schedules separately classify packing materials and raw materials, component parts and inputs, showing a clear legislative distinction between them. The 1993 exemption notification and the 1998 rate notification use the same language as the Act and therefore cannot be construed to include packing materials within raw materials, component parts or inputs. Explanation II to the 1998 notification does not alter that position, because it applies to goods that are brought into a local area for use as raw materials, component parts or inputs, and packing materials are not within that category. The scheme of the Entry Tax Act cannot be expanded by reference to sales tax provisions, excise jurisprudence, or the Tea Marketing Control Order, all of which operate in different statutory contexts.

Conclusion: Packing materials are not raw materials, component parts or inputs for the purpose of the Entry Tax Act or the notifications in question, and the assessee was not entitled to exemption or the concessional 1% rate on that basis.

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