ORDER 1. This revision petition has been filed by M/s Trishool Bakery, The Mall, Simla, under Section 31 of the Himachal Pradesh General Sales Tax Act, 1968 (hereinafter referred to as the Act) against the orders of the Excise & Taxation Commissioner, dated 22-7-1977, whereby he had remanded the case of the petitioners to the Assessing Authority Simla, for deciding the case afresh. 2. The facts, in brief, leading to the present petition are as follows. The petitioners, who are dealers in bakery goods, were assessed to pay sales tax under Section 4 (6) (c) of the Act. Their contention that they should be exempted from payment of tax under Section 7 read with item No. 40 of Schedule B of the Act, because neither power was used in manufacture of any of their bakery goods nor the goods were cold in containers and packets, did not find favour with the Assessing Authority, who held that they were liable to pay sales tax under the Act. 3. Aggrieved by the above orders, the petitioners filed an appeal before the Deputy Excise & Taxation Commissioner, Simla, who remanded the case to the Assessing Authority with the directions that it may be ascertained, after verification on the spot, whether or not the bakery goods were being sold in containers and packets. The petitioners again went in appeal to the Excise and Taxation Commissioner against the aforesaid orders, who, while upholding the orders of the Deputy Excise & Taxation Commissioner, further directed the Assessing Authority to take into account whether the process of slicing bread by a power-driven machine would take away the entitlement to exemption from payment of tax under the Act. Dissatisfied with these orders, the petitioners have come in revision before this court. 4. I have heard the learned counsel for the petitioners as also the Excise & Taxation Officer (LegalCell), representing the Excise & Taxation Department, and gone through the record of proceedings before the lower authorities, carefully. The learned counsel for the petitioners has taken me through the provisions of Section 7 read with item No. 40 of Schedule B of the Act and vehemently argued that in the light of these provisions,, the petitioners were clearly entitled to exemption from sales tax on their bakery goods, which were neither being sold in packets or containers nor required use of power in their preparation. Elaborating his argument, he pointed out that bakery goods were sold in paper wrappers or paper bags/ cartons which could not be described as containers or packets. The use of paper wrappers, bags/cartons was made for the convenience of the customers who had the option of taking the goods in open condition. Further, no power was being used at all in the manufacture/preparation of the bakery goods at any stage. 5. On the other hand, the representative of the Excise & Taxation Department has argued that even wrappers and paper cartons/bags would constitute containers/packets within the meaning of the Act and further since bread was sliced by a power-driven machine, it did not lie in the mouth of the petitioners to contend that no power was used in the preparation of bread. Referring to the provision of item No. 40 of Schedule b of the Act, he argued that the petitioners would have been entitled to the exemption allowed under Section 7 of the Act only if their goods were being sold in open condition without being put in paper bags/cartons or wrappers. 6. I have given careful consideration to the arguments led on behalf of both the parties. The main points to be considered are ;— (i) Whether use of power-driven machine for slicing bread would amount to use of power in the preparation of bread and ; (ii) Whether paper wrappers and bags/cartons, in which the goods are sold can be termed as packets and containers. Before proceedings to give my findings on these issues, reference to Section 7(1) and item No. 40 of Schedule B of the Act, is necessary, which read as follows :— Section 7 of the Act (I) "No tax shall be payable on the sale of goods specified in the first column of Schedule ‘B’ subject to the conditions and exceptions if any, set out in the corresponding entry in the second column thereof and no dealer shall charge sales tax on the sale of goods which are declared tax free from time to time under this section." Item No. Col. I Col. II 40 of Schedule B of the Act. Bakery goods prepared without using power at any stage. When sold otherwise than in containers and packets by bakers dealing exclusively in such goods, 7. I Col. II 40 of Schedule B of the Act. Bakery goods prepared without using power at any stage. When sold otherwise than in containers and packets by bakers dealing exclusively in such goods, 7. Reverting to the issues raised during arguments I shall, in the first instance, proceed to dispose of the issue whether use of a power-driven machine for slicing bread would constitute use of power in the preparation of bread or not. A plain reading of the provision of item 40 above makes it manifestly clear that only bakery goods which are prepared by using power are to be excluded from the purview of this item and Section 7 of the Act. Here the case of the Excise & Taxation Department is not that bread is prepared by using power but that after its preparation it is sliced with the help of a power-driven machine. The words used in item 40 above viz., prepared without using power at any stage are significient and material for deciding this issue. It is a matter of common sense that after the bread is baked, the process of preparation of the bread is complete and it is ready for sale. Thus, I do not find any force in the argument led by the representative of the Excise & Taxation Department that since bread is sliced with the help of a power-driven machine, it is not to be exempted from tax. In the circumstances, I cannot but hold that slicing of bread with a power-driven machine does not amount to use of power in its preparation and, therefore, the petitioners are entitled to exemption provided under item No. 40 of Schedule B read with Section 7 of the Act. 8. Coming to the next point, it is an admitted fact that all bakery goods and bread are brought to the shop open in trays and displayed for sale in covered glass-cases. It is only when the customer wants to take the goods home, that they are wrapped in paper or put in paper bags/ cartons. Big cakes, e. g. wedding cakes, birthday cakes etc., are not even put in paper cartons/bags and are supplied open, set on a wooden board. It is only when the customer wants to take the goods home, that they are wrapped in paper or put in paper bags/ cartons. Big cakes, e. g. wedding cakes, birthday cakes etc., are not even put in paper cartons/bags and are supplied open, set on a wooden board. The point at issue is whether these paper bags/cartons and wrappings in paper can be described as containers/packets within the meaning of the provision under item 40 of Schedule B of the Act. It is common knowledge that even small commodities sold by street vendors are given to customers, for their convenience, in paper bags or wrapped in paper, unless the customers want to carry them in their own bags or baskets. Certainly, these paper/ cartons/bags and wrappings cannot be described as containers or packets. The word container carries with it the suggestion that it is made of metal, tin, hard-board wood or stiff card board. Containers are always made of sufficiently hard material which is resistant to damage through normal handling, for carriage of certain commodities over long distances by rail or road. Packets in common parlance would mean commodities packed in tough paper/wax paper, which very often have a protective cellophane coverings and are properly sealed, e. g. packets or biscuits, manufactured by large industrial concerns and supplied throughout the country. These packet cannot be easily opened and are also resistant to damage through normal handling, so that they do not tear or break open in transit. It is an accepted principle of interpretation of statutes that the Legislature does not use any word superfluously and any word used in the statute had to be given its popular, natural and ordinary meaning. It would be relevant at this point to examine carefully the exact wording in Column 2 of Item 40 of Schedule B of the Act which reads as under :— "When sold otherwise than in containers and packets by bakers dealing exclusively in such goods." The word when here is equivalent to if and both the words together are very relevant and significant in the context of the issue being discussed. The expression when sold clearly suggests that only in case the goods are offered for sale in readymade packets or containers, they would be liable to tax. The expression when sold clearly suggests that only in case the goods are offered for sale in readymade packets or containers, they would be liable to tax. As brought out earlier, the various cakes and pastries are displayed in glass-top cabinets, kept in open condition and not in readymade packets or containers. It is only after they have been sold, that they are put in paper bags/paper cartons or wrapped in paper, according to the quantity purchased and required by the customer. It cannot, therefore, be said that these bakery goods are sold in containers or packets. 9. In view of my above findings on the issues involved in this case, the revision petition is accepted and the impugned orders of the lower Excise and Taxation Authorities are hereby quashed. 10. To be communicated. Petition allowed -