JUDGMENT RAJU, J. - The appellant is the assessee and is dealing in packing materials, and during the assessment years 1977-78, the assessee was assessed on a taxable turnover at Rs. 2,97,975 at 4 per cent. On realising the mistake in doing so and the correct position of law that on and from September 13, 1977, with the introduction of entry 7A, the levy of tax had to be at 15 per cent in respect of turnover in question for the period from September 3, 1977 to March 31, 1978, the turnover was refixed by an order dated January 3, 1980, of course after giving due opportunity to the appellant, at Rs. 2,83,665 taxable at 4 per cent and for the period from September 13, 1977 to March 31, 1978, the turnover was fixed at Rs. 31,433 taxable at 15 per cent. Objecting to the said assessment, on the ground that the polythene rolls and sheets do not find a place in the First Schedule, an appeal was preferred before the first appellate authority contending that the polythene rolls and sheets were used only as packing materials by the purchasers, and consequently, they did not come under any entry of the First Schedule to the Act. It was also contended that the assessing officer went wrong in holding that the polythene rolls and sheets are nothing but polythene films. The first appellate authority came to the conclusion that the manufactured product dealt with by the assessee is nothing but polythene sheet which used to be converted into blocks and that this has nothing to do with the films, which could come under the First Schedule. On that basis, the first appellate authority held that the presumption of the assessing officer that it falls within the clause of "films" cannot be sustained. As a matter of fact the first appellate authority also noticed the position that polythene sheets are being sold in rolls also. In such circumstances, the revised order of the assessing officer was set aside by the first appellate authority. As a matter of fact the first appellate authority also noticed the position that polythene sheets are being sold in rolls also. In such circumstances, the revised order of the assessing officer was set aside by the first appellate authority. While the matter stood thus, the Joint Commissioner invoking his suo motu powers of revision under section 34 of the Tamil Nadu General Sales Tax Act, 1959, after issuing a show cause notice and after considering the objections of the appellant and after hearing the authorised representative, came to the conclusion that the polythene sheets dealt with by the assessee is a thin skin and answers the description of "films". He was also of the view that the "film" may be in the form of sheet and flat piece of thin material. The Joint Commissioner also considered the question on a comparative analysis of entries 6, 7 and 7-A of the First Schedule and ultimately found that entry 7-A introduced with effect from September 13, 1977, takes within its purview all films known to the trade and irrespective of the fact that the films are sold in the form of sheets or bags, they continue to be films within the meaning of entry 7-A for the purpose of taxation under the Act. Aggrieved thereby the present appeal has been filed by the assessee. For a proper appreciation of the issue raised for our consideration, the entries 6, 7 and 7-A to the First Schedule may be set out as hereunder : ------------------------------------------------------------------------------------ 6. Original entry : ------------------------------------------------------------------------------------ Cinematographic equipment At the point of 7 01-04-1959 including cameras, projectors, first sale in the 10 01-09-1963 sound recording and State. reproducing equipment, 11 01-12-1965 lenses, films and parts and 12 18-06-1967 accessories required for use therewith. 15 26-02-1970 ------------------------------------------------------------------------------------ 7. Original and present entry ------------------------------------------------------------------------------------ Photographic and other At the point of 7 01-04-1959 cameras and enlargers, first sale in the 10 01-09-1963 lenses, films, plates, papers, State. cloth and other parts and 11 01-12-1965 accessories required for use 12 18-06-1967 therewith. 15 26-02-1970 ------------------------------------------------------------------------------------ 7-A. Original entry (item 7-A omitted) : ------------------------------------------------------------------------------------ All kinds of films (other At the point of than those specified first sale in the 15 13-09-1977 elsewhere in this Schedule). State. cloth and other parts and 11 01-12-1965 accessories required for use 12 18-06-1967 therewith. 15 26-02-1970 ------------------------------------------------------------------------------------ 7-A. Original entry (item 7-A omitted) : ------------------------------------------------------------------------------------ All kinds of films (other At the point of than those specified first sale in the 15 13-09-1977 elsewhere in this Schedule). State. ------------------------------------------------------------------------------------ No doubt by Act 39 of 1978, item 7-A came to be omitted from July 1, 1978, and this omission does not in any way affect the consideration for the assessment year in question. A careful and analytical consideration of the entries referred to above would indicate that films connected with cinematography is contemplated for inclusion in entry 6 and films connected with photographic and other cameras are meant to be covered under entry 7 and entry 7-A was specifically designed to cover "all kinds of films (other than those specified elsewhere in the Schedule)". Consequently, on and from September 13, 1977, with introduction of entry 7-A in the First Schedule, an item or commodity need not necessarily be a film connected with cinematography or films pertaining to photographic and other cameras to be considered or categorised as film for the purpose of taxation, inasmuch as such of those categories of films which do not fall under the classification visualised under entries 6 and 7 would still fall under entry 7-A provided the commodity concerned answers the description "all kinds of films" and if it is also shown that it does not fall under any other items specified under the First Schedule. The question as to what a film is may be considered first in the light of some of the meanings contained in the standard dictionaries in use. In the condensed Chemical Dictionary - 10th Edition revised by Gessner G. Hawley, the word "film" is dealt with at page 462 in the following terms : "Film - An extremely thin, continuous sheet of a substance which may or may not be in contact with a substrate. There is no precise upper limit of thickness, but a reasonable assumption is 0.010 inch. The protective value of any film depends on its being 100 per cent continuous, i.e., without holes or cracks, since it must form an efficient barrier to molecules of atmospheric water vapor, oxygen, etc. A long chain fatty acid or alcohol on water produces a film whose 'thickness' is the length of one molecule (about 200A). The protective value of any film depends on its being 100 per cent continuous, i.e., without holes or cracks, since it must form an efficient barrier to molecules of atmospheric water vapor, oxygen, etc. A long chain fatty acid or alcohol on water produces a film whose 'thickness' is the length of one molecule (about 200A). The fatty acid molecules are oriented with the radical and in the water. Such films are good evaporation barriers and have been successfully imposed on glass. Soap bubbles are elastic films about one micron thick and have considerable strength. Film forming agents (drying oils) are essential in paints and lacquers. Oxide films formed automatically on the surface of aluminium protect it from corrosion. Thin material oxide films are widely used in electronic and semiconductor devices. Electro-deposited metals (chromium, copper, nickel) are conventionally (and perhaps illogically) called coatings. The term film is also applied to sheets of cellophane, polyethylene, polyvinylidene chloride, etc., used for wrapping and packaging of food products, meats and poultry (especially shrirack films, which are stretched before application). These function as moisture vapor barrier. Plastic films are also used as slip surfaces in concrete structures such as air strips, ice-rinks and highways. Photographic film is made from cellulose acetate." In Webster's Third New International Dictionary (Volume I, A to G) at page 850 the word "film" is dealt with. The meaning as given therein in so far as it is relevant for our purpose may be extracted as hereunder : "b(1) a thin often flexible transparent sheet (as of cellophane, polyethylene, rubber or an adhesive) used esp. as a wrapping or packaging material. ...." From the above, it could be seen that the term "film" will fit in with reference to and also is applied to sheets of polythene used for wrapping and for packing food products, meats and poultry and that the mere fact that the polyethylene films in the shape of sheets are used for packing purposes or converted into packing materials, does not in any manner undermine or alter the inherent character and nature of the film. The meaning of the word "film" as could be seen from the condensed Chemical dictionary is also in tune with the common usages and the word "film" cannot be given a restricted meaning as is sought to be contended for by the assessee or as held by the First appellate authority. The meaning of the word "film" as could be seen from the condensed Chemical dictionary is also in tune with the common usages and the word "film" cannot be given a restricted meaning as is sought to be contended for by the assessee or as held by the First appellate authority. The assumption of the first appellate authority that the polythene sheets which could be converted into bags cannot be brought within the term "films" under the First Schedule, has no basis or reason whatsoever and the view expressed by the first appellate authority seems to proceed merely on surmises with no basis as referred to already. The consideration by the first appellate authority appears to be perfunctory and without any reference to various classifications and the pattern and system in-built in entries 6, 7 and 7-A in the First Schedule. As noticed by us earlier entry 7-A is purposely and deliberately couched in wide terms so as to encompass within its fold the other categories of films not separately specified elsewhere and in our view, the nature and kind of the film dealt with by the petitioner will squarely fall under and has to be brought under entry 7-A, and the only restriction so far as the said entry being that a film to come under should not otherwise fall under any other entry specified elsewhere in the First Schedule. We are, therefore, of the view that entry 7-A has been couched in a most comprehensive language and in widest possible terms with a view to bring in every other type or kind or sort of film but not specified elsewhere in the Schedule and it could not be contended that what are specifically enumerated in item 6 or 7 alone answer the description of films. We are, therefore of the view that the Joint Commissioner was right in invoking his suo motu power of revision to set aside the orders of the first appellate authority, which as found by us supra, suffers from serious infirmity in law, and no exception could be taken to the conclusion of the Joint Commissioner that the commodity dealt with by the petitioner really falls within entry 7-A of the First Schedule to the Act on and from September 13, 1977. The learned counsel for the appellant next contended that the Joint Commissioner has committed an error in subjecting the entire turnover of the whole assessment year to tax at 15 per cent that the same cannot be sustained. As we have found supra, but for the entry 7-A of the First Schedule introduced with effect from September 13, 1977, the commodity dealt with by the petitioner could not have been brought either under entry 6 or 7 and as rightly done by the assessing officer, the turnover, for the period prior to September 13, 1977 would only be subjected to the multi-point rate of tax at 4 per cent during the relevant period under the general charging provision. The learned counsel for the Revenue could not effectively meet this objection taken by the learned counsel for the appellant. When the assessing officer himself has given sufficient reasons to apply different rates of tax for different periods, having regard to the position of entries at the relevant time, the Joint Commissioner was not justified either in law or on facts to have interfered with the order of the assessing officer also so as to deprive the appellant of payment of lesser rate of tax in respect of turnover for the period prior to September 13, 1977 during the assessment year in question. The order of the Joint Commissioner in so far as it levied 15 per cent tax as against 4 per cent really due on a turnover of Rs. 2,83,665 shall stand set aside, and the said turnover shall be liable to tax only at 4 per cent. The assessing officer shall take further steps to implement the order in the light of the directions contained above. In the result, the T.C. (A) is partly allowed as indicated above and in other respects the same is dismissed. No costs. Petition partly allowed.