JUDGMENT The judgment of the Court was delivered by DR. B. P. SARAF, J. - By this reference under section 61(1) of the Bombay Sales Tax Act, 1959, made at the instance of the assessee, the Maharashtra Sales Tax Tribunal has referred the following question of law to this Court for opinion : "Whether, on a true and correct interpretation of section 15A of the Bombay Sales Tax Act, 1959, the Tribunal was correct in its conclusion that sales tax was payable on the tins purchased from unregistered dealers in which oil purchased from registered dealers was packed and sold ?" 2. It is obvious from the above question that the controversy involved in this reference is in a narrow compass and the determination of the same depends on the construction of section 15A of the Bombay Sales Tax Act, 1959 ("the Act"). The material facts giving rise to this reference, briefly stated, are as follows : The assessee is a dealer in oil. He purchased oil from registered dealers within the State of Maharashtra as also from other sources. During the period from November 8, 1980 to October 27, 1981, to which this reference relates, the assessee purchased empty tins from unregistered dealers which were used for packing of the oil purchased by it from the registered dealers. The assessee was assessed under the Act for the above period by the Assistant Commissioner of Sales Tax (Assessment), Bombay, by his order of assessment dated July 30, 1984. In the above order of assessment, the Assistant Commissioner determined the taxable sales of tins by adding gross profits to the value of the purchase of empty tins from unregistered dealers to the extent of Rs. 7,21,673 and levied tax thereon at the rate of 4 per cent which was the rate applicable to sales of oil within the State at the material time. The assessee was aggrieved by the levy of sales tax at the rate of 4 per cent on the value of tins supplied by its along with the oil at the rate of four per cent, as according to it, no sales tax was leviable on the sales of oil effected by it and that being so, no tax could be levied on the value of tins also which were used as containers for packing such oil. The assessee, therefore, appealed to the Deputy Commissioner of Sales Tax (Appeals). The Deputy Commissioner allowed the appeal of the assessee and set aside the levy of sales tax at the rate of four per cent on the sale value of tins estimated by the Assistant Commissioner (Assessment). Subsequently, the Additional Commissioner of Sale Tax initiated proceedings for suo motu revision under section 57(1)(a) of the Act and revised the appellate order of the Deputy Commissioner and restored original order of the Assistant Commissioner (Assessment). This he did as he was of the opinion that on a proper interpretation of section 15A of the Act, sales tax was leviable on the value of tins at the rate of four per cent at which the sales and purchases of oil were "generally" subjected to tax under the Act. Aggrieved by the order passed by the Additional Commissioner of Sales Tax on suo motu revision, the assessee appealed to the Maharashtra Sales Tax Tribunal ("the Tribunal"). It was contended by the assessee before the Tribunal that under section 15A of the Act, sales of tins used by the assessee in packing of oil sold by it was not liable to any tax because the rate of tax on the sales of oil effected by the assessee was nil in the instant case. The case of the assessee, in other words, was that the containers cannot be taxed in the hands of the dealer at a rate different from the one at which the contents are taxed. This contention of the assessee did not find favour with the Tribunal. The Tribunal was of the opinion that by virtue of section 15A of the Act, sales of containers would be taxable at the rate applicable to the sales of the contents, by the assessee in the given case. The Tribunal, therefore, dismissed the appeal of the assessee. Hence this reference at the instance of the assessee. 3. Section 15A of the Act was inserted in the Act by the Bombay Sales Tax (Amendment) Act, 1962 (Maharashtra Act 21 of 1962), with effect from July 15, 1962. This section, as it stood at the material time, reads as follows : "15A. Rate of tax on packing materials. Hence this reference at the instance of the assessee. 3. Section 15A of the Act was inserted in the Act by the Bombay Sales Tax (Amendment) Act, 1962 (Maharashtra Act 21 of 1962), with effect from July 15, 1962. This section, as it stood at the material time, reads as follows : "15A. Rate of tax on packing materials. - Where any goods are sold or purchased and such goods are packed in any materials the tax shall be leviable on the sales or purchases of such packing materials (whether such materials are separately charged for or not) at the same rate of tax (if any) as is applicable to the sales or purchases, as the case may be, of the goods themselves." The object of inserting section 15A, which is evident from the statement of objects and reasons, was to make provision for levy of tax on the sale or purchase of packing material used in the packing of goods sold, at the same rate at which the goods packed were subject to tax. 4. It is evident from a plain reading of the above section that it applies only where any goods sold or purchased are packed in any materials ("packing material"). It is not relevant for the application of this section whether such materials are separately charged or not. But once the goods sold or purchased are packed in any material, by virtue of section 15A, tax shall be leviable on the sales or purchases of such materials at the same rate (if any) as is applicable to the sales or purchases of the goods themselves. The only controversy is in regard to the true meaning of the expression "at the same rate of tax (if any) as is applicable to the sales or purchases, as the case may be, of the goods themselves". According to the assessee, it means the rate of tax, if any, applicable to sale or purchase of the goods by the dealer concerned. If no tax is leviable on the sales of any goods effected by a particular dealer, no tax can be levied on the sales of packing materials also. The Revenue does not accept this interpretation of section 15A. If no tax is leviable on the sales of any goods effected by a particular dealer, no tax can be levied on the sales of packing materials also. The Revenue does not accept this interpretation of section 15A. According to it, packing materials sold with the goods would be taxable at the rate specified in the Schedule against the goods packed, and the fact that sale of such goods by the assessee is not taxable under the Act for one reason or the other, is not relevant in deciding the rate of tax applicable to the sale of packing material. 5. We have considered the rival submissions and carefully perused section 15A of the Act as it stood at the material time. We have also noticed the object of enactment of section 15A. At the time this section was inserted, there was a great deal of controversy in regard to the levy of tax on the value of containers used in packing the goods sold by a dealer which were either exempt from tax, or taxable at a rate lower than the rate at which the packing materials, if separately charged, would have been assessed. The contention of the assessee in all such cases was that the packing materials were supplied free along with the goods packed therein and hence there was no sale of packing materials. The Revenue always felt that there was an implied sale of containers or packing materials and hence the value of such packing materials was liable to tax. All this gave rise to a spate of litigation at different forums including the High Courts and the Supreme Court. In each case it became necessary to decide whether there was a sale of packing materials, express or implied. Tests were laid down by the Supreme Court to find out whether there was an implied sale of packing materials or the packing materials were used by the seller as a convenient vehicle of transport in which event implied sale of packing material cannot be inferred. Tests were laid down by the Supreme Court to find out whether there was an implied sale of packing materials or the packing materials were used by the seller as a convenient vehicle of transport in which event implied sale of packing material cannot be inferred. It was to set at rest all such controversies and to simplify the task of the assessing officers that in the Bombay Sales Tax Act, section 15A was inserted to do away with the necessity of ascertaining price component of packing material from the value of the contents for subjecting the same to tax separately at the rates applicable to sale or purchase of such packing material. The section, in effect, provides that the sale of containers, implied or express, along with the goods which are packed therein, would be deemed to be the sale of the goods themselves and treated accordingly for the purpose of levy of sales tax under the Act. It is in this context that the expression "at the same rate of tax (if any), as is applicable to the sales or purchases, as the case may be, of the goods themselves" has been used. We are of the clear opinion that on a proper construction of section 15A, the expression "rate of tax, as is applicable to sales or purchases of the goods themselves" means the rate which is actually applicable to sales of goods in a given case. Where no sales tax is leviable on the sales of goods by the dealer, he cannot be asked to pay any tax on the sales of packing materials. Obviously, the "rate of tax applicable to the sale of goods themselves" would mean the rate factually applicable and not the rate at which such goods are "generally" subjected to tax. Had that been the legislative intent, section 15A would have been worded differently. In fact, the Legislature has done so by substituting the words "as is applicable to the sales or purchases, as the case may be, of the goods themselves" by the words "as is set out in the relevant Schedule against such goods packed". This change was made by Maharashtra Act 9 of 1989 with effect from April 1, 1989. This amendment fully supports the opinion of ours that sales of packing materials cannot be subjected to any tax, if no tax is leviable on the goods themselves. This change was made by Maharashtra Act 9 of 1989 with effect from April 1, 1989. This amendment fully supports the opinion of ours that sales of packing materials cannot be subjected to any tax, if no tax is leviable on the goods themselves. Or to put it differently, the rate of tax referred to in unamended section 15A is the rate qua sale of goods by the dealer. It does not and cannot mean the rate generally applicable to sales or purchases of the goods packed in the packing material. Any other interpretation would be contrary to the express language of section 15A and would amount to substituting words "at the same rate of tax (if any) as is applicable to the sales or purchases, as the case may be, of the goods themselves" by the words "at the same rate of tax as is 'generally' applicable to sales or purchases of goods under the Act". This cannot be done because of the well-settled principle of interpretation that a statutory enactment must ordinarily be construed according to the plain natural meaning of its language and that no words should be added, altered or modified unless it is plainly necessary to do so in order to prevent a provision from being unintelligible, absurd, unreasonable, unworkable, or totally irreconcilable with the rest of the statute. 6. In fact, as stated before, section 15A has been amended to provide that packing materials would be taxable not at the rate applicable to sale or purchase of the goods themselves, but at the rate as is set out in the relevant Schedule against such goods packed. After this amendment, the rate of tax applicable to the sale of packing materials is no more related to the rate applicable to the sale of goods by the dealer. It is now related to the rate specified in the Schedule against the goods packed. Whether the goods packed are not taxable in a given transaction of sale or are taxable at a lower rate than the rate specified in the Schedule, would be no more relevant in deciding the rate of tax applicable to packing material in which it is packed under the amended section 15A. 7. Whether the goods packed are not taxable in a given transaction of sale or are taxable at a lower rate than the rate specified in the Schedule, would be no more relevant in deciding the rate of tax applicable to packing material in which it is packed under the amended section 15A. 7. In view of the above, we are of the clear opinion that the Tribunal was not correct in holding that sales tax was payable on the tins used for packing of oil, at the rate specified in Schedule C to sales of oil, when admittedly no tax was payable on the sales of oil effected by the assessee in the instant case, which was packed in such packing material. 8. Accordingly, we answer the question referred to us in the negative and in favour of the assessee. 9. In the facts and in the circumstances of the case, there shall be no order as to costs. Reference answered in the negative.