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    <title>2022 (6) TMI 772 - MADRAS HIGH COURT</title>
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    <description>Packing materials purchased for use in vanaspathi packing were not eligible for concessional tax under Form XVII during the assessment years before the 12 March 1993 amendment to section 3(3) of the Tamil Nadu General Sales Tax Act, 1959; the tin containers were treated as packing goods rather than manufacturing inputs, so concessional treatment was denied. Breach of the statutory condition attached to that concession attracted penalty under section 23, so penal liability was upheld. However, the penalty ceiling under section 23 limited the levy, and the quantum was reduced from the higher percentage imposed below to 50%.</description>
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      <description>Packing materials purchased for use in vanaspathi packing were not eligible for concessional tax under Form XVII during the assessment years before the 12 March 1993 amendment to section 3(3) of the Tamil Nadu General Sales Tax Act, 1959; the tin containers were treated as packing goods rather than manufacturing inputs, so concessional treatment was denied. Breach of the statutory condition attached to that concession attracted penalty under section 23, so penal liability was upheld. However, the penalty ceiling under section 23 limited the levy, and the quantum was reduced from the higher percentage imposed below to 50%.</description>
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