JUDGMENT U. L. BHAT, C.J. - The following question of law has been referred to this Court by the Appellate Tribunal (Board of Revenue) at the instance of the Revenue under section 44(1) of the M.P. General Sales Tax Act, 1958. English rendering of the question will be as follows : "Whether, in the facts and circumstances of the case, the Tribunal was justified in holding that bamboo crates are covered by entry 15, Part IV of Schedule II of the M.P. General Sales Tax Act, 1958, prior to October 1, 1978 ?" 2. Assessee is a registered dealer. He purchases bamboos, makes bamboo creates out of the same and sells the crates. The assessment year is from November 11, 1977 to October 31, 1978. Goods used as containers and packing material are covered by entry 15, Part IV of Schedule II of the M.P. General Sales Tax Act, 1958 (for short, "the Act") and at the relevant time, the sales tax was at the rate of to per cent. If bamboo crates do not fall under the above entry, they attract the residuary entry in Part VI of Schedule II attracting sales tax at the rate of 10 per cent. The assessing authority and the appellate authority held against the assessee and levied sales tax at the rate of 10 per cent. The Tribunal, in further appeal, upheld the case of the assessee and held that sales tax was payable only at the rate of 5 per cent till October 1, 1978, when a notification was issued specifying "bamboo khanchas" as containers or packing materials. 3. Entry 6 of Part IV of Schedule II, as it stood prior to 1978 till it was amended by Amending Act No. 25 of 1978, reads as follows : "6. Goods for use as containers and packing material, that is to say - (i) gunny bags and hessian; (ii) jute twine; (iii) cardboard boxes and cartons; (iv) empty tins and empty barrels; (v) wooden boxes (khokas) and tin boxes; (vi) empty bottles and corks; (vii) polythene packing materials; (viii) paper labels; (ix) tin seals; (x) paper bags; (xi) wooden frames; (xii) paper cones.; The entry was amended and definition "packing material" was introduced by inserting section 2(jj) in the Act by the Amending Act No. 25 of 1978 which came into effect on October 1, 1978. "Packing material" is defined as follows : "'Packing material' means such containers or other materials used in the packing of the goods for sale as are specified in entry 15 of Part IV of Schedule II." Entry 6 was renumbered as entry 15, clause (xi) was amended and clause (xiii) was inserted. Entry 15, as amended, reads thus : "Goods for use as containers and packing materials, that is to say - (i) gunny bags and hessian; (ii) jute twine; (iii) cardboard boxes and cartons; (iv) empty tins and empty barrels; (v) wooden boxes (khokas) and tin boxes; (vi) empty bottles and corks; (vii) polythene packing materials; (viii) paper labels; (ix) tin seals; (x) paper bags; (xi) wooden reels and frames; (xii) paper cones; (xiii) such other goods as may be notified as containers or packing material." 4. The position on or after October 1, 1978, can admit of no doubt. Entry 15 deals with goods for use as containers and packing materials. The expression "packing material" is defined as containers or those materials used in packing of goods for sale as are specified in entry 15. The particular kind of goods, in order to be regarded as packing material on or after October 1, 1978, must fall within the description of the categories specified in entry 15. The purpose of using the words "that is to say" in entry 15 is to limit the goods which can fall under entry 15. Nevertheless, in order to infuse a degree of flexibility, the Legislature conferred on the competent authority power to notify other goods as containers or packing materials. There can be no doubt that entry 15 is intended to be exhaustive and not merely illustrative. This view finds support from the decision of the Supreme Court in Sait Rikhaji Furtarnal v. State of Andhra Pradesh [1992] 85 STC 1; (1991) Supp. 1 SCC 202, relying on the earlier decision in State of Tamil Nadu v. Pyare Lal Malhotra [1976] 37 STC 319. 5. The position could not be different prior to October 1, 1978, though the Act, as it then stood, did not contain the definition of "packing material" and the clause (xiii) of entry 6. That is the effect of use of the words "that is to say" in entry 6 of the Act, as it stood prior to October 1, 1978. The position could not be different prior to October 1, 1978, though the Act, as it then stood, did not contain the definition of "packing material" and the clause (xiii) of entry 6. That is the effect of use of the words "that is to say" in entry 6 of the Act, as it stood prior to October 1, 1978. Bamboo crates were not specified as packing material in entry 6 and, therefore, the residuary entry in Part VI of Schedule II would apply. 6. On October 1, 1978, a notification was issued specifying 10 categories of goods as packing materials for the purpose of entry 15. The additional 10th item is "bamboo khanchas". Bamboo khancha is bamboo crate. This cannot be regarded as clarificatory. 7. In the result, we answer the question in the negative, i.e., in favour of the Revenue and against the assessee. 8. A copy of this order under the signature of the Registrar and seal of the High Court be forwarded to the Board of Revenue. Reference answered in the negative.