B.R. ARORA, J.—These three revision petitioner raise a common question of law and, therefore, I propose to decide all these revision petitions by a common judgment. For the proper understanding of the case, the facts of S.B.. Sales Tax Revision No. 963/87 M/s. Mukesh Prathisthan vs. Commercial Taxes Officer are taken into consideration. 2. The assessee petitioner is a dealer dealing in packing material, stationery, medicine, straw board etc at Jasol, Balotra. For the assessment year 1976-77 and 1977-78 the petitioners sales for kesophane packing material was initially assessed at the rate of 4% while completing the assessment under section 10 of the Rajasthan Sales Tax Act. The assessing authority thereafter reopened the assessment of the assessee petitioner for these 2 years under section 12 of the Act after issuing notice to the petitioner, and while completing the assessment, came to the conclusion that the kesophene packing material is chargeable at the rate of 7% under the residuary clause and cannot be charged as packing material at the rate of 4%. The assessing authority also charged the interest under Section 113 of the Rajasthan Sales Tax Act on the enhanced tax so levied. Dissatisfied with the order passed by the Assessing Authority the assessee preferred appeals before the Deputy Commissioner (Appeals) Commercial Taxes Jodhpur who by his judgment dated 8th of June, 1984 allowed both the appeals filed by the assessee, set aside the demand raised by the assessing authority as well as the interest charged under section 11 of the Sales Tax Act. While deciding the appeals the Deputy Commissioner (Appeals) came to the conclusion that kesophane packing material is covered under entry G of the entries which contain polythene and alkathaene packing material. Aggrieved with the order passed by the Deputy Commissioner (Appeals) allowing the appeals of the assessee the Revenue preferred appeals before the Rajasthan Salex Tax Tribunal Ajmer and the Tribunal by its judgment dated 30.10.1987 allowed both the appeals filed by the Revenue and set aside the order passed by the Deputy Commissioner (Appeals) and restored the order passed by the Assessing Authority and held that tax on kesophene packing material is leviable at the rate of 7% under the residuary clause and it is not covered under entry G, relating to the packing material. 3. I have heard learned counsel for the parties. 3. I have heard learned counsel for the parties. The main contention of Shri Vineeth Kothari, counsel for the petitioner is that kesophene packing material falls under entry G of the entry relating to the packing material. According to him, entry G is sufficiently wide and covers the kesophene packing material also. According to the learned counsel for the petitioner, kesophene is a product name given buy its manufacturer in a trade but actually it is a cell-phone. In support of his contention, the learned counsel for the petitioner has placed reliance over Shri Ram Trading Co. Vs. State of Kerala (1). He has also placed reliance over the definition of the word "cell-phone" given in Encyclopaedia Britannia Micro Vol. 2 page 673. The other contention of the counsel for the petitioner is that interest under section 118 of the Act cannot be charged in the present case. In support of this contention, he has placed reliance over the judgment, of the Rajasthan High Court in Commercial Taxes Officer vs. Malwaya Minerals and Motor Parts (2). 4. Mr. P.K. Bhansali, appearing before the Revenue on the other hand, has supported the judgment passed by the Tribunal and according to him no question of law arises in the present case and as such the revision petition is not maintainable. His submission is that the judgment of the Sales Tax Tribunal is based on the Division Bench judgment of the Rajasthan High Court in Century Ecko vs. State of Rajasthan (3). According to him the list issued with the notification containing the packing material is exhaustive and it is. not an illustrative one and, therefore, whatever the names have been included in the list only those items are to be changed at the rate of 4% and the items which are not included in the list are to be charged under the residuary clause at the rate of 7%. The entry regarding the kesophene packing material has been included for the first time in the year 1979 and, therefore, prior to that sales tax on kesophene packing material is to be charged at the rate of 7%. i.e. under the residuary clause. 5. Now I take up the history of the imposition of tax by the State Government of packing materials. The State Government by its notification. i.e. under the residuary clause. 5. Now I take up the history of the imposition of tax by the State Government of packing materials. The State Government by its notification. F.5 (21) FD (CT) 71-3 dated March 27, 1971, in exercise of its powers under section 5 of the Rajasthan Sales Tax Act notified with immediate effect the rate of tax payable by the dealer at the rate of 3% in respect of packing material i.e. to say.......polythene and alkathene packing material Again by notification No.F. 2(8) F. D. Gr. IV/75/9 dated July 1, 1975 the State Government issued a fresh notification providing the list of rate of tax payable by a dealer in respect of goods specified in column No. 2 of the list and providing the rate of tax payable thereon as in column No. 3 of the list. The notification issued by the Government is as under :-- S. No. 285 F. 2 (8) FD. Gr. IV/75-9 dated 1.7.75. S.D. 52 : In exercise of the powers conferred by S.5 of the RST Act, 1954 the Govt. of Rajasthan being of the opinion that it is expedient in the public interest to do so, hereby provides that the rate of tax payable by a dealer in respect of the goods specified in column 2 of the list annexed hereto shall be as shown against them in column 3 of the said list. S.No. Description of goods Rate of tax. 1 ..... 2 ..... 3 ..... 4 ..... 5 ..... 6 ..... 7 ..... 8. Packing material, that is to say ,-- 4% (a) Gunny bags and hession. 193 (b) Jute twins. (c) Craft paper and craft bags. (d) Empty tins and empty barrels. (e) Empty bottles and corks. (f) Wooden boxes (khokhas) and tin boxes. (g) Polythene and alkathene packing material. (h) Bituminised packing material. 4% 9.. 10 ..... 11 ..... 12 ..... 13 ..... 14 ..... 15 ..... 16 ..... 17 ..... 18 ..... The list was further amended by a further notification No. F.4 ()FD.Gr. IV/79 dated 5.3.79 :-- 429. F. 4( ) F.D. Gr. IV/79-3-dated 5.3.79. S.0.216-In exercise of the powers conferred by S. 5 of the RST Act, 1954, the State Govt. 10 ..... 11 ..... 12 ..... 13 ..... 14 ..... 15 ..... 16 ..... 17 ..... 18 ..... The list was further amended by a further notification No. F.4 ()FD.Gr. IV/79 dated 5.3.79 :-- 429. F. 4( ) F.D. Gr. IV/79-3-dated 5.3.79. S.0.216-In exercise of the powers conferred by S. 5 of the RST Act, 1954, the State Govt. being of the opinion that it is expedient in the public interest to do so, hereby makes with immediate effect the following amendments in this Department Notification No. F. 2 (B) FD Gr. IV/75-9 dated the 1.07.1975 (S.No. 285) Pub. in the Rajasthan Gazette Extraordinary. Part. IV (C) H. dated 1.07.1975, namely :- Amendment in the said notification against item No. 8 of the list appended there to— (a) in column No. 2., at item (9) for the expression "polythene and alkathene packing materials", the expression "plastic packing materials" shall be substituted; (b) for full stop at the end of item No. (h), comma. shall be substituted; and after item No. (h) as amended, the following item shall be added namely;-- (i) paper bags, (j) paper labels, (k) paper cuttings, (1) tin seals (m) crown corks and pilfer proof caps." This notification was further amended by the State Government vide notification No. F. 4 (3) FD. Gr. IV/79-10 dated 13.6.79 published on 21.6.79. S. No. 447: F. 4 (3) GD Gr. IV/79-10 dated 13.6.79, pub. on 21.6.79. S.O. 137- In exercise of the powers conferred by S.5 of the RST Act, 1954, the State Govt, being of the opinion that is it expedient in the public interest so to do, hereby makes, with immediate effect, the following amendment in this department notification No. F. 2 (8) FD Gr. IV/75-9 dated 1.7.1975 (S.No. 285), pub. in the Rajasthan Gazette, Extraordinary, Part IV-C (II) dated 1.7. 1975 namely :-- Amendment in the said notification, against serial No. 8 of the list appended there to. In column 2 (a) for full stop "." at the end of item No. (m). IV/75-9 dated 1.7.1975 (S.No. 285), pub. in the Rajasthan Gazette, Extraordinary, Part IV-C (II) dated 1.7. 1975 namely :-- Amendment in the said notification, against serial No. 8 of the list appended there to. In column 2 (a) for full stop "." at the end of item No. (m). comma "," shall be substituted; and (b) after item (n) as so amended, the following new item shall be added, namely :-- "n) Kesophane packing material." Thus by amendment dated 5th of March, 1979, the State Government in the entry G of clause (8) substituted plastic packing material in place of polythene and alkathene packing material, and by notification dated 21.06.1979, added a new item No. namely, kesophene packing material. 6. Now, therefore, two questions arise for the determination of this Court— (1) Whether kesophene packing material is covered by entry G in clause (8) of the notification prior to 21.06.1979 when specifically this entry was added by the notification. (2) Wether the interest under section 118 of the Act can be charged if the Court comes to the conclusion that the kesophene packing material during the relevant period is chargeable at the rate of 7%. 7. Question No. 1 : I will take first question first. It is an admitted fact that kesophene packing material as such was not included in the entry prior to 21.6.79. The entry at the relevant time contains only polythene and alkathene packing material. As kesophene packing material has not been included in the list and, therefore, it has to be ascertained from the way or the manner in which this kesophane packing material is treated or understood by the persons who deal in or use these things. The entry G contains polythene and alkathene packing materials only. The meaning of word "polythene" has been given in the Rancom House Dictionary of the English language as polyethenelene and according to this Author polyethylene means- a plastic polymer of ethylene (CH2 CH2) used chiefly for containers, electrical insulation and packing and also called polythene." According to Webester III New International Dictionary the word "Polythene" means polyethylene used as a plastic. According to Webester the polyethylene means- a polymer of ethylene est. According to Webester the polyethylene means- a polymer of ethylene est. one of a group of partially crystalline light weight thermoplastics; there have good resistance to chemicals, low moisture absorption and good insulating properties that very from soft to hard and from tough and flexible to rigid according to the conditions of manufacture (as at high, medium, or atmospheric pressure) and the type of catalyst, and that are used chiefly in the form of film (as in good packing and garment bags) pips and tubling as moulded products (as squeeze bottles and other containers and as electrical insulation asp. in cables." So far as alkathene is concerned, that is a commercial product of polythene and, therefore, both polythene and alkathene packing material are one and the same thing and one is the commercial product and the other is the basic product. Now so far as the question whether the list appended to the notification charging the sales-tax at the rate of 4% is exhaustive or illustrative that point stands concluded by the three Division Bench judgments of the Rajasthan High Court as well as by the Supreme Court. It has been held in State of Tamil Naidu Vs. Pyarelal Malhotra (4), Raj. I.S.M. Association (P) Ltd. Vs. Commercial Taxes Officer (5) and Centaury Ecka Vs. State of Rajasthan (supra) that the expression "that is to say" in the notification is apparently meant to exhaustively enumerate all kinds of good in the list appended to the notification. It is thus clear that the items "packing material" included at No. 8 in the notification consist of varieties of packing material enumerated in the notification and the varieties specified in the list were exhaustive of the kinds of packing materials on which the sales tax is paid at the rate of 4%. The counsel for the petitioner though argued that the kesophane packing material is covered by entry G and the main plank of his argument is that the kesophene packing material is nothing but a cell-phone which is covered under the entry EG of the notification. In support of his case, he relied upon the observations made in Shri Ram Trading Co. Vs. State of Kerala (supra) where after considering the various definitions and the concession given by the counsel for the revenue, the Court opined that kesophene cellulose film is only a trade name. In support of his case, he relied upon the observations made in Shri Ram Trading Co. Vs. State of Kerala (supra) where after considering the various definitions and the concession given by the counsel for the revenue, the Court opined that kesophene cellulose film is only a trade name. It was agreed in that case both by the assessee as well as by the Department that it is cello phone. Whether kesophene is a cello phone or not though reference of various books was made, but the point was not decided by the Kerala High Court in that case as it was agreed between the assessee as well as the department that it is cello phone. The Word "cell-phone" has been defined in Encyclopedia Britannica Vol. 2 Micro Paedia as under :— Cellphone Means regenerated cellulode extruded into twin, flat, transparent sheet. Extrusion though a small hole or spinneret, produces a fibre rayon highly impermeable to dry gases, grease, and bacteria, cell-phone is used chiefly to package food and other perishables. It is frequently given a moisture proof coating and is some times dyed. In the manufacture process, an alkaline solution of cellulose fibres (usually wood or cotton) known as viscose is extruded through a narrow slit into an acid bath. The acid regenerates the cellulose, forming a film, further treatment such as washing and bleaching yields cell-phone. The name is trade marked in some countries. Chemical properties and packing used." The main stress of the counsel for the petitioner is that kesophene packing material is nothing but cell-phone packing material and he has not thrown any light whether this kesophene or cell-phone is covered under the entry G. It is not in dispute that for the first time this item kesophene packing material was inserted by the notification in the list of packing material as a new item as item No. N in the list, According to the notification this is a new item. But I am concerned with the entries existed prior to 21st of June, 1979. Prior to 21.6.79 there was no entry relating to kesophene packing material. The entry polythene and alkathene packing material do not include kesophene packing material as the entry is exhaustive and not general and no wide meaning can be given to the term polythene and alkathene packing material. Prior to 21.6.79 there was no entry relating to kesophene packing material. The entry polythene and alkathene packing material do not include kesophene packing material as the entry is exhaustive and not general and no wide meaning can be given to the term polythene and alkathene packing material. Even other- wise also, looking to the meaning of polyethylene, it cannot be said that kesophene is covered by entry EG which contains polythene and alkathene packing materials only. When the main item is followed by the words "that is to say" it clearly denotes that the articles enumerated specifically in the list is only comprised in the category and that category would constitute a separate class for sales tax. The Government has power to grant exemption or to charge tax at low rate on the various products made by a common basic product and each product mentioned in the list is to be charged at the particular rate which has been mentioned in the list. Merely because the basic product is the same, it cannot be said that all the products made from the basic product are the same for the purpose of charging the tax at the same rate. The Government is competent to determine which articles should be taxed in what manner and at what rate. The notification by which the entry kesophene packing material has been added also shows that it was a new item and not the item already covered by the entry and therefore, it cannot be said that the item kesophene packing material was covered by the entry polythene and alkathane packing material. In this view of the matter, I am of the opinion that the entry EG contained polythene and alkathene packing material does not cover the kesophene packing material and the Tribunal was justified in charging the tax on kesophane packing material at the rate of 7% as chargeable in the residuary clause. 8. Now coming to the second point whether any interest under Section 118 of the Act can be charged in the present case on the additions made. This point squarely stands covered by the judgment of the Rajasthan High Court in Commercial Taxes Officer Vs. Nalwaya Minerals and Motor Parts (Supra) wherein it has been held that no interest is leviable on assessment made under section 12 of the Act prior to the amendment which was made on 1.4.87. This point squarely stands covered by the judgment of the Rajasthan High Court in Commercial Taxes Officer Vs. Nalwaya Minerals and Motor Parts (Supra) wherein it has been held that no interest is leviable on assessment made under section 12 of the Act prior to the amendment which was made on 1.4.87. In the case in hand, the petitioner assessee was already assessed under section 10 (3) of the Sales Tax Act and the tax was charged on these items at the rate of 4%. Later on the case was reopened under section 12 of the Act and the notice was issued to the petitioners and the assessment was made under section 12 of the Act. As the present case related to the assessment year 1976-77 and 1977-78 and, therefore, no interest under section 118 of the Act can be charged from the petitioner on the additions made by the assessing authority while completing the assessment under section 12 of the Rajasthan Sales Tax Act. 9. In the result, all the three revision petitions filed by the petitioners are allowed in part. The charge of sale tax on the kasophene packing material at the rate of 7% under the residuary clause for the assessment year 1976-77 and 1977-78 is maintained, but the interest levied by the Tribunal is set aside.