RAMESH RANGANATHAN, J. ( 1 ) THE question of law which arises for consideration, in these batch of Tax revision cases filed by the State of A. P against the order of the sales Tax Appellate Tribunal in T. A. Nos. 894 of 2002 and batch dated 31-3-2004, is:- "whether gunnies which have suffered tax within the State of A. P, can, under Section 6-C of the APGST Act, again be subjected to tax when they are sold along with the contents, despite the prescription in Entry 19 of the 1st Schedule that Gunnies, sold with or without its contents, are liable to be taxed only at the point of first sale in the State?" facts, in brief, are that the respondents, in these batch of tax revision cases, are rice millers and registered dealers under the APGST act. In respect of some of the assessees, the Commercial Tax Officers finalized assessments exempting the value of gunnies purchased from local registered dealers in the State. The contention, that under Entry 19 (iii) of the First Schedule to the A. P. G. S. T. Act gunnies were taxable at the first sale point, was accepted by the assessing authorities and tax was levied only at 1% under Section 5 (A) of the A. P. G. S. T. Act. The Deputy commissioners (CT) took up revision of assessment, under Section 20 (2) of the A. P. G. S. T. Act, in so far as it related to exemption of second sale of gunnies from being taxed and, invoking Section 6-C of the A. P. G. S. T. Act, revised the assessment levying tax at 4% on the turnover of gunnies at the same rate of tax as applicable to the rice contained therein. Aggrieved thereby, the dealers preferred appeals before the Sales Tax Appellate tribunal. In respect of a few other assessees, the Commercial Tax officers themselves followed the reasoning of the Deputy Commissioners (CT) and levied tax at 4% on the turnover of gunnies sold along with rice. ( 2 ) THE Deputy Commissioner (CT) dismissed the appeals preferred against such orders of assessment. Aggrieved thereby, the dealers preferred appeals before the Sales Tax Appellate Tribunal (S. T. A. T ). ( 2 ) THE Deputy Commissioner (CT) dismissed the appeals preferred against such orders of assessment. Aggrieved thereby, the dealers preferred appeals before the Sales Tax Appellate Tribunal (S. T. A. T ). The S. T. A. T, by order dated 31-3-2004, held that Section 6-C of the APGST Act would not apply, to gunnies which had already suffered tax within the State and that APGST suffered gunnies were not liable to be taxed again when they were sold along with rice to the Food Corporation of India. Aggrieved thereby the present batch of T. R. Cs, all of which relate to the assessment years 1997-98 to 2000-2001, are filed by the State of andhra Pradesh. ( 3 ) SRI K. Raji Reddy, Special Standing Counsel for Commercial Taxes, would contend that the non obstante clause in the amended Section 6-C is"notwithstanding anything contained in Section 5, 5f, 6 and Section 6a" of the Act and when packing material is sold along with goods, it shall suffer tax at the rate at which its contents are to be taxed notwithstanding what has been provided for in Section 5 (1) read with the first schedule to the apgst Act. Learned Special Standing Counsel would submit that, while section 5 (1) is subject to other provisions of the APGST Act and requires tax to be paid at the rates of tax and at the point of levy specified in the schedules, Section 6-C which relates to levy of tax on packing material is notwithstanding anything contained in Section 5. The rate of tax payable on packing material, when sold along with the goods, would therefore be the same as that of the goods packed or filled, irrespective of whether or not packing material had earlier suffered tax within the State. Learned special Standing counsel would submit that though the point of levy is not specifically mentioned in Section 6 (c), which only mentions the rate of tax, the point of levy shall be deemed to have been included in the substantive provision of Section 6-C in view of the non obstante clause contained therein. According to the Learned Special Standing Counsel, Section 6-C is also a charging Section and has an overriding effect over Section 5 (1) of the Act. According to the learned Special Standing Counsel, Section 6-C is divisible into three distinct parts viz. According to the Learned Special Standing Counsel, Section 6-C is also a charging Section and has an overriding effect over Section 5 (1) of the Act. According to the learned Special Standing Counsel, Section 6-C is divisible into three distinct parts viz. , (1) Over-riding provision with non-obstante clause employing the words "notwithstanding anything contained in section 5, 5-F, 6 and 6-A"; (2) Substantive provision prescribing that "the rate of tax on packing material sold with the goods shall be the same as that of goods packed or filled"; and (3) Deeming provision in the form of "whether or not there is separate sale or agreement for sale for the packing material and the goods packed or filled. "learned Special Standing Counsel would further submit that when gunnies are sold with rice, the deeming provision in Section 6-C would come into operation and since rice is taxed at 4%, the gunnies which contain rice are also required to be taxed at 4%. Learned counsel would place reliance on kcp (Ramakrishna Cement) Ltd Vs. Commercial Tax officer, 2002 34 APSTJ 198. Premier Breweries Vs. State of Kerala, 1998 108 STC 598. and Associated Cement Companies Limited vs. Govt. of A. P. , 2000 31 APSTJ 149. Sri V. Bhaskar Reddy, learned counsel for the respondents, would support the order of the Sales Tax Appellate Tribunal and submit that the assessees had purchased empty gunnies from registered dealers within the State paying sales tax thereon, they had sold rice to FCI along with gunnies and as gunnies, with or without goods, are exigible to tax at the point of first sale within the State, the turnover relating to gunnies is not exigible to tax once-again. According to the learned counsel, Section 6-C of the APGST Act would have no application when gunnies have already been subjected to tax as it does not provide for a situation, where packing material is required to be taxed again, even when it had earlier suffered tax within the state. Learned counsel would contend that, under Entry 19 of the first Schedule, there is only one commodity i. e, gunnies . When it is sold without contents, a particular rate of tax is prescribed and when the same commodity is sold with contents, the rate of tax is the one applicable to its contents. Learned counsel would contend that, under Entry 19 of the first Schedule, there is only one commodity i. e, gunnies . When it is sold without contents, a particular rate of tax is prescribed and when the same commodity is sold with contents, the rate of tax is the one applicable to its contents. The point of levy, in both situations, is at the point of first sale within the State. When gunnies have already suffered Tax under the apgst Act, at the point of first sale within the State, and if the very same gunnies are used for the purpose of sale of rice, it cannot be taxed again as it would then amount to multi-point levy of tax on gunnies contrary to what has been specifically provided for in the first schedule under the heading goods in respect of single point tax as leviable under section - 5", whereunder, If gunnies are sold without contents for the first time in the State it attracts 4% and similarly if gunnies are sold along with contents for the first time in the State, it shall suffer tax at the rate at which its contents are liable to tax. Learned counsel, while conceding that gunnies when purchased from outside the State or manufactured within the State and sold for the first time with its contents, would suffer tax at the same rate at which its contents are to be charged as it amounts to first sale of gunnies within the State, would however contend that in cases where gunnies purchased are those which have already suffered tax, under the APGST Act, and the very same gunnies are used for sale of rice, it cannot be subjected to tax again under Section 6c of the APGST act. Learned counsel would submit that Section 6c of APGST Act prescribes only the rate of tax on packing material and would apply only when the packing material is liable to tax. If the packing material used, is not liable to tax, it cannot be said that, by virtue of Section 6c, it can again be subjected to tax. Learned counsel would submit that Section 6c of APGST Act prescribes only the rate of tax on packing material and would apply only when the packing material is liable to tax. If the packing material used, is not liable to tax, it cannot be said that, by virtue of Section 6c, it can again be subjected to tax. Learned counsel would submit that when the legislature deliberately did not mention the words "point of levy" in Section 6c of the APGST Act, taxing statutes could not be interpreted by adding words thereto so as to make out some presumed object of the Legislature, as the law is well settled that in case of doubt, an interpretation which is beneficial to the tax payer must be adopted. Reliance is placed by the learned counsel on "state of Kerala and others Vs. C. M. Francis and company, 1961 12 STC 122. in this regard. ( 4 ) LEARNED counsel would submit that sale of gunnies, by the respondents, are secondary sales as the gunnies were purchased from registered dealers within the State and therefore the value of gunnies, used as containers for rice, could not be taxed again at their hands. Learned counsel would further submit that Section 6-C, unlike Sections 5, 5-A, 6 and 6-A, is not a charging Section even by legal fiction and would place reliance on "govind Saran Ganga Saran v. Commissioner of sales Tax, 1985 60 STC 1. wherein the Supreme Court held thus:"the components which enter into the concept of a tax are well known. The first is the character of the imposition known by its nature which prescribes the taxable event attracting the levy, the second is a clear indication of the person on whom the levy is imposed and who is obliged to pay the tax, the third is the rate at which the tax is imposed, and the fourth is the measure or value to which the rate will be applied for computing the tax liability" ( 5 ) LEARNED counsel would submit that, under the unamended Section 6-C, there was a deemed sale of packing material along with its contents and amendment to Section 6-C has only resulted in its being made explicit as it is now clearly provided that sale of goods would include sale of the containers which contain the goods sold. Learned counsel would submit that since Section 6-C is not a charging section, it does not apply to second sale of gunnies whether sold with, or without, its contents. Learned counsel would also submit that if Section 6-C were interpreted to include second sale of gunnies, it would amount to gunnies being taxed at multiple points which was not the intention of the Legislature since gunnies are included in the First Schedule and not in the Sixth Schedule, learned counsel would submit that, except for the Sixth Schedule, all other schedules to the APGST Act relate to goods which are exigible to single point tax and if the Legislature intended to tax gunnies at multi- points, it would have been included in the Sixth Schedule instead of under the First Schedule to the APGST Act. ( 6 ) THE Sales Tax Appellate Tribunal (hereinafter referred to as the "tribunal"), relying on the judgment of this Court in M/s Raasi Cement limited Vs. Commercial Tax Officer, Miryalguda, 24 APSTJ 100. held that even after amendment of Section 6c, the decision of the Supreme Court in raj Sheel Vs. State of A. P. , AIR 1989 SC 1696 . holds good and that the burden lies on the assessing officers to establish that the price of the container is a component of the sale price of the contents and that it is necessary for the assessing authority to go into the question of ingredients of sale or agreements for sale of container, where contents are packed and sold with the packing material, for the purpose of taxing the container under the amended Section 6-C also. The Tribunal held, that under Section 6c only the rate of tax on packing material has been prescribed and would apply only when gunnies were sold for the first time along with the goods at the rate applicable to the goods contained in it, that Section 6-C did not provide that even if the packing material had already suffered tax it should be taxed again, whenever it is sold along with the goods, at the rate at which the goods are to be charged and if it were to be so interpreted, it would yield absurd results, and may well result in a situation where the very same gunny may have to suffer tax several times whenever it is used though gunnies were treated as single point tax goods. The Tribunal relied on Raj Sheel (7 supra) wherein the Supreme Court ( 7 ) HELD that where the packing material is an independent commodity and the packing material and its contents are sold independently, packing material is liable to be taxed on its own footing and whether a transaction for sale of packing material is an independent transaction or not would depend upon several factors. The Tribunal held that packing material, in the batch of cases before it, i. e. "gunnies" satisfied five such factors mentioned in the Judgment in Rajsheel (7 supra.) It was a commodity having its own identity and was separately classified in the schedule, it would not undergo any change either at the time of packing or at the time of using the content, it was capable of being re-used after the contents had been consumed, it was used for convenience of transport and the quantity of goods was not dependent on the packing. The Tribunal held that the mere fact that the consideration for the packing material had merged with the consideration for the product, would not make the sale of gunnies an integral part of the sale of the product. The Tribunal expressed its inability to agree with the contention that ( 8 ) SECTION 6c is deemed to have covered the point of levy also in view of the non-obstante clause, and held that in the absence of a specific mention regarding the point of levy in Section 6c of the APGST Act, it could not be said that in view of the non-obstante clause, it covered the point of levy also. The Tribunal held that the non-obstante clause had been used in section 6c with a view to convey that irrespective of the rate of tax fixed, either in the Sections or the schedules or any where in the APGST Act, the rate of tax shall be the same rate as applicable to the contents, and therefore APGST tax suffered gunnies were not liable to be taxed again when these gunnies were sold along with rice to F. C. I. The Tribunal however made it clear that if the dealers had already collected tax on the value of gunnies also from the Food Corporation of India, they were not entitled for refund of tax. ( 9 ) BEFORE we proceed to examine the respective contentions, it is necessary to refer briefly to the provisions of the APGST Act more particularly Section 6-C, both prior to and after its amendment. Section 6-C was introduced by the APGST (Amendment) Act (Act no. 11 of 1984)j, and then read as follows:"6-C Levy of tax on packing material: Notwithstanding anything in Sections 5 and 6-A where goods packed in any materials are sold or purchased, the materials in which the goods are so packed shall be deemed to have been sold or purchased along with the goods and the tax shall be leviable on such sale or purchase of the materials at the rate of tax, if any, as applicable to the sale, or, as the case may, purchase of goods themselves"in Raj Sheel (7 supra), the Supreme Court held that Section 6-C provides, by legal fiction, that the packing material shall be deemed to have been sold along with the goods, and although there was no sale of packing material it would be deemed that there was such a sale, in which event, Section 6-C declared that tax would be leviable on such deemed sale of the packing material at the rate of tax applicable to the sale of the goods themselves. The Supreme Court held that Section 6-C could, at best, be regarded as a provision by way of clarification of the existing legal situation, and the contention that a rate applicable to the packing material in the Schedule should be applied to the sale of such packing material in a case under Section 6-C, could not be accepted since in fact that there was no such sale of packing material and it was only by legal fiction, and for a limited purpose, that such sale could be contemplated. Section 6-C was substituted, by A. P. Act 22 of 1995, with effect from 1. 4. 1995. The amended Section 6-C reads as follows:"6-C Levy of tax on packing material: Notwithstanding anything contained in section 5, Section 5f, Section 6 and Section 6a, the rate of tax on packing material sold with the goods shall be the same as that of the goods packed or filled, whether or not there is separate sale or agreement for sale for the packing material and the goods packed or filled. " ( 10 ) IN Rajsheel (7 supra), the Supreme Court held that a transaction of sale may consist of a sale of the product and a separate sale of the container housing the product with respective sale considerations for the product and the container separately; or it may consist of a sale of the product and a sale of the container but both sales being conceived of as integral components of a single sale transaction; or what may yet be a third case, it may consist of a sale of the product with the transfer of the container without any sale consideration thereof. The question in every case would be a question of fact as to what are the nature and ingredients of sale. When the Supreme Court decided Raj Sheel (7 supra) on 16-5- 1989, referring to the three modes of the sale of contents and the containers the unamended section 6c was in force and the commodity "gunnies" was enumerated under entry 157 of the 1st Schedule to the apgst Act. When the Supreme Court decided Raj Sheel (7 supra) on 16-5- 1989, referring to the three modes of the sale of contents and the containers the unamended section 6c was in force and the commodity "gunnies" was enumerated under entry 157 of the 1st Schedule to the apgst Act. It was subsequently, by Act 30 of 1997, that entry 157 was omitted w. e. f. 12-5-1997 and "gunnies" were brought under entry 19 (iii) of the 1st Schedule to the APGST Act under two distinct and different sub- headings namely "gunnies without contents" under sub-entry (a) and "gunnies with contents" under sub-entry (b ). It would be appropriate to refer, in juxtaposition, to the provisions of section 6c as it stood before its amendment and as it now stands after its amendment. Un-amended Provision amended Provision 6-C levy of tax on packing Material Notwithstanding anything in Sections 5 and 6-A, where goods packed in any materials are sold or purchased, the materials in which the goods are so packed shall be deemed to have been sold or purchased along with the goods are so packed shall be deemed to have been sold or purchased along with the goods and the tax shall be leviable on such sale or purchase of the materials at the rate of tax, if any, as applicable to the sale, or as the case may be, purchase of goods themselves. 6-C Levy of tax on packing material. Notwithstanding anything contained in Section 5, Section 5f, Section 6 and Section 6-A, the rate of tax on packing material sold with the goods shall be the same as that of the goods packed or filled, whether or not there is separate sale or agreement for sale for the packing material and the goods packed or filled. ( 11 ) SRI K. Raji Reddy, learned Special Standing Counsel would place reliance on Premier Breweries (2 supra) to contend that as Section 5 (5) of the Kerala General Sales Tax Act is in paramateria with the amended section 6c of the APGST Act, the APGST Tax suffered gunnies are liable to be taxed again when they are sold along with their contents. On the other hand, Sri V. Bhaskar Reddy, learned counsel for the respondents, would place reliance on Raasi Cement Ltd (6 supra), wherein this court, referred to Section 5 (3-D) of the Karnataka General Sales Tax Act, which had come up for consideration before the Apex Court in Vasayadatta cements v. State of Karnataka, 101 STC 168. In Raasi Cements (6 supra), this court, on examining the amended Section 6-C with reference to Section 5 (3d) of the Karnataka Sales Tax Act held that notwithstanding the phraseology of the amended Section 6-C, the assessing authority had to determine in each case the ingredients of the contract of sale relating to containers and also the intention of the parties in accordance with the judgment in Raj Sheel (7 supra ). ( 12 ) IN order to appreciate the rival contentions in this regard, it is appropriate to extract the relevant provisions, contained in the Karnataka general Sales Tax Act, the Kerala General Sales Tax Act and the Andhra pradesh General Sales Tax Act, in Juxtaposition: section 6-C of APGST Act section 5 (5) of Kerala General Sales Tax Act section 5 (3) (D) of Karnataka General Sales Tax Act notwithstanding anything contained in Section 5: Section 5f of, Section 6 and Section 6a, the rate of tax on packing material sold with the goods shall be the same as that of the goods packed or filled, whether or not there is separate sale or agreement for sale for the packing material and the goods packed or filled. Note:- This Section is substituted by Act 22/95 with effect from 1. 4. 1995. Note:- This Section is substituted by Act 22/95 with effect from 1. 4. 1995. Notwithstanding anything contained in sub-section (1) or Sub-Section (2), but subject to sub-Section (6), where goods sold are contained in containers or are packed in any packing materials, the rate of tax and the point of levy applicable to such containers or packing materials, as the case may be, shall, whether the price of the containers of the packing materials is charges separately; or not, be the same as those applicable to goods contained or packed, and in determining the turnover of the goods the turnover in respect of the notwithstanding anything contained in this Act, where goods sold or purchased are contained in containers are packed in any packing materials, liable to tax under this Act, the rate of tax and the point of levy applicable to turnover of such containers or the packing materials as the case may be, shall, whether the container or the packing materials have already been subjected to tax under this Act or not or whether the price of the containers or of the packing materials is charged for separately or not be the same as those applicable to goods contained or containers or packing materials shall be calculated there under; Section 5 (6):- Where the sale or purchase of goods contained in any containers or packed in any packing materials is exempt from tax, then the sale or purchase of such containers or packing materials shall also be exempt from tax. packed. Proviso: That no tax under this sub-section shall be leviable if the sale or purchase of goods contained in such containers or packed in such packing materials in exempt from tax under this Act. Note: Inserted w. e. f. , 1. 4. 1986. ( 13 ) SECTION 5 (5) of Kerala GST Act, specifically mentions that the rate of tax and point of levy shall be the same as applicable to the goods contained in the packing material, and that in determining the turnover of the goods, the turnover in respect of the containers or packing materials shall be calculated there under (emphasis supplied ). Similarly Section 5 (3-D) of the Karnataka Sales Tax Act provides that the rate of tax and the point of levy applicable to the turnover of the packing material shall be the same as applicable to the goods packed, whether the packing material has already been subjected to tax under the Act or not (emphasis supplied ). Section 6-C neither provides for the point of levy and the determination of turnover as prescribed in Section 5 (5) of the Kerala General Sales Tax Act nor does it provide, as is prescribed in Section 5 (3-D) of the Karnataka General Sales tax Act that, whether the packing material has already been subjected to tax under the Act or not, the rate of tax and the point of levy applicable to the container shall be the same as the goods placed therein. The Tribunal held that the A. P. State Legislature did not choose to specifically state that irrespective of the point of levy, packing material is to be charged again when it is sold along with the goods at the same rate at which the goods are to be charged, while the Karnataka State Legislature, as early as on 1-4-1986 had, in Section 5 (3-D), specifically prescribed that the rate of tax and the point of levy applicable to the turnover of the packing material shall be that of its contents, whether the packing material had already been subjected to tax or not, the A. P. State Legislature did not choose to introduce such words in Section 6c of the APGST Act, obviously for the reason that they did not intend to tax packing material once-again when it was sold along with the goods, in case the packing material had suffered tax earlier under the APGST Act. The Tribunal held that If the A. P. State Legislature had intended to levy tax on packing material, more than once, they would have specifically provided for the same in the amended Section 6c of APGST Act, which came into force from 1-4-1995, and that the law laid down in Premier Breweries (2 supra) had no application to the amended Section 6c of APGST Act, as the principle laid down in Mis. Raj Sheel (7 supra) had not been overruled and had only been distinguished for the reason that the corresponding provisions in Kerala GST Act and the A. P. General Sales Tax Act were not similar. The Tribunal held that in so far as the principle laid down in rajsheel (7 supra) is concerned, this Court in Raasi Cements Limited (6 supra) had held that the principles laid down therein holds good even after amendment of Section 6c of the APGST Act. ( 14 ) BEFORE examining the question as to whether absence of the words, ". . . . . and the point of levy applicable. . . . . . . . . and in determining the turnover of the goods the turnover in respect of the containers or packing materials shall be calculated thereunder" in Section 5 (5) of the Kerala General Sales Tax Act and ". . . . . . . and the point of levy applicable. . . . . whether the container or the packing materials have already been subjected to tax under this Act or not. . . . . . " in Section 5 (3-D) of the Karnataka General Sales Tax Act, in Section 6-C of the apgst Act would, as has been held by the Tribunal, result in APGST tax suffered gunnies not being liable to be taxed again under Section 6- c. when they are sold along with its contents, the judgments relied on by both counsel would require to be considered. ( 15 ) IN "vasavadatta Cements (8 supra), the constitutional validity, of section 5 (3-D) of the Karnataka General Sales Tax Act, was in question. The Supreme Court held that the observations in Raj Sheel s case (7 supra), wherein the unamended Section 6-C of the APGST Act, was under consideration, was equally applicable to Section 5 (3-D) of the Karnataka general Sales Tax Act and the liability for Sales Tax, on the Gunny bags used for packing the Cement sold by the dealers, had to be considered having regard to the facts of each case after determining what are the ingredients of the contract and the intention of the parties in accordance with the decision in Raj Sheel (7 supra ). ( 16 ) THE constitutional validity of amended Section 6-C was in question in Raasi Cement Ltd (6 supra) and a declaration was sought that the amended Section 6-C had no application in respect of transactions of Sale or Purchase of containers which were specifically dealt with under Items 157 of the First Schedule. The Division Bench of this Court, while holding section 6-C as a constitutionally valid piece of legislation, held :- "section 6-C provides that the rate of tax on packing material sold with the goods shall be the same as that ot the packed or tilled goods, whether or not there Is separate sale or agreement tor sale for the packing material and the goods packed or filled. Though neither the underlined words nor their substance was part of unamended Section 6c of the Act, the purport of the same is incorporated in Section 5 (3-D) of the KST Act, by enacting "whether the price of the container or ot the packing material is charged tor separately or not". this leads to the enquiry as to whether the presence ot those words will make any difference in interpreting Section 6-C. We are unable to accede to the contention of the learned Government Pleader that by incorporating the underlined words in the impugned provision the enquiry into the question of fact with regard to ingredients ot sale and intention ot the parties, directed by the Supreme Court in raj Sheet s case in each case is dispensed with and that in view of those words now it is not necessary for the assessing authority to go into the question of ingredients of sale or agreement for sale of container where contents (goods) are packed and sold with the packing material (container) and the intention ot the parties for the purpose of taxing the container under the impugned provision as, in Vasavadatta Cements case, the Supreme Court held:". . . . . . . . . . . we are of the view that the High Court was in error in construing the provisions of Section 5 (3-D) to hold that the Legislature has thought it fit and convenient to treat the sale of goods contained in a container as an integrated single transaction of sale of the goods and that it makes it unnecessary to analyse the components of a particular sale and enter upon investigation to find out the real price at which the packing material is purported to have been sold, and separate it from the computation of the turnover regarding the particular goods which was packed on the packing materials or housed in the container"that point is res integra and we cannot but hold that irrespective of incorporating the underlined words in the impugned provision treating the first mode ot sale on the same tooting as the second mode ot sale, noted above, wherein the price of the container is treated as a component of the sale price of the contents in goods packed or filled, the assessing authority is not absolved of the obligation ot determining what are the ingredients or the contract and the intention of the parties in accordance with the decision of the Supreme Court in raj Sheel s case as also in Vasavadatta Cement s case the question which arose for consideration, in Premier Breweries (2 supra), was as to whether the value of packing material could be included in the value of its contents for the purpose of levy of Tax under section 5 (5) and (6) of the Kerala General Sales Tax Act. The Supreme court held that in Vasavadatta (8 supra), the Court had overlooked the marked dissimilarity between pre-amended Section 6-C of the APGST Act and Section 5 (3-D) of the Karnataka General Sales Tax Act and that sub- sections (5) and (6) of Section 5 of the Kerala General Sales Tax Act had to be construed uninfluenced by the decision in Raj Sheel (7 supra ). The supreme Court held thus:-"moreover, the packing materials as such are not being taxed under sub- section (5) of Section 5 of the Act. The subject matter of Tax are the goods packed in the containers. In calculating the turnover of the goods, packing materials will have to be taken into account. The supreme Court held thus:-"moreover, the packing materials as such are not being taxed under sub- section (5) of Section 5 of the Act. The subject matter of Tax are the goods packed in the containers. In calculating the turnover of the goods, packing materials will have to be taken into account. The packing materials will be taxed at the same rate and at the same point as the goods contained in the packing material. This is because the goods are sold packed in containers and are charged accordingly. This is a rule of computation of the turnover of the goods. If no tax is ultimately found leviable on the goods then no tax can be levied on the containers in which the goods are contained. " ( 17 ) THE constitutional validity of Entry 18 of the First Schedule as introduced by A. P. Act 27 of 1996 was the subject matter of challenge in associated Cement Companies Ltd (3 supra ). While upholding the vires of the said Entry, the Division Bench of this Court held thus:- "the new Section 6-C introduced by Act 22 of 1995 is almost in pari materia with sub sections (5) and (6) of Section 5 of the Kerala Genral Sales Tax Act which was interpreted by the Supreme Court in Premier Breweries Vs. State of kerala (108 STC 598 ). Sub-Sections (5) and (6) of Section 5 of the said Act reads as under:"notwithstanding anything contained in sub-section (1) of sub-section (2), but subject to sub-section (6) where goods sold are contained in containers or are packed in any packing materials, the rate of tax and the point of levy applicable to such containers or packing materials, as the case maybe, shall, whether the price of the containers or the packing materials is charged separately or not be the same as those applicable to goods contained or packed, and in determining turnover of the goods, the turnover in respect of the containers or packing materials shall be included therein. ""5 (6) Where the sale or purchases of goods contained in any containers or packed in any packing materials is exempt from tax, then, the sale or purchase of such containers or packing materials shall alsobe exempt from tax. " ( 18 ) THE situation is the same here. ""5 (6) Where the sale or purchases of goods contained in any containers or packed in any packing materials is exempt from tax, then, the sale or purchase of such containers or packing materials shall alsobe exempt from tax. " ( 18 ) THE situation is the same here. The legal position enunciated above will apply with full force to the interpretation of Section 6-C and Entry 18 of the First schedule to APGST Act. The decision in Premier Breweries case establishes beyond doubt that there is nothing anomalous or incongruous in prescribing the same rate of tax for the packing materials as well as the goods packed irrespective of the fact whether they are charged for and sold separately. . . . . . . . . . . . " the Constitutional validity of amended Section 6-C, of the APGST act, was again the subject matter of challenge in The K. C. P. Cements (1 supra) and while rejecting the challenge, the Division bench of this Court held:-"section 6-C of the A. P. G. S. T. Act, unmistakably and without giving any scope for any other interpretation, has legislatively declared that the rate of tax. on packing material sold with the goods should be the same as that of the goods packed or filled, whether or not there is separate sale or agreement for sale for the packing materials and goods packed or filled. Even if there is a separate agreement of sale in respect of the goods packed and the packing material, the assessing authority is left with no discretion but to tax, the container and the goods packed separately, by virtue of the deeming clause introduced in the provisions of Section 6-C of the A. P. G. S. T. Act. Even if there is a separate agreement of sale in respect of the goods packed and the packing material, the assessing authority is left with no discretion but to tax, the container and the goods packed separately, by virtue of the deeming clause introduced in the provisions of Section 6-C of the A. P. G. S. T. Act. In Premier Breweries s case, on considering the provisions of Section 5 (5) of the Kerala General Sales tax Act which is in pari materia with the provisions of Section 6-C of the a. P. G. S. T. Act and after referring to the two cases in Raj Sheet s case and vasavadatta cement s case, the Supreme Court opined that the point of tax and rate of tax on containers and packing material shall be the same as that of the goods sold even where containers or packing materials are sold separately"in none of the aforementioned judgments, has the question raised in the present batch of tax revision cases, arisen for consideration. It is therefore necessary to consider this question in the light of the scheme of the APGST Act and the provisions therein. ( 19 ) NON-OBSTANTE Clause: section 6-C has a non-obstante clause. A non-obstante clause is generally appended to a Section with a view to give the enacting part of the Section, in case of conflict, an overriding effect over such other provisions of the Act as are mentioned in the non-obstante clause. It is equivalent to saying that in spite of the provisions of the Act mentioned in the non-obstante clause, the provision following it will have full operation or the provisions embraced in the non-obstance clause will not be an impediment for the operation of the enactment or the provision in which the non-obstante clause occurs. (Principles of Statutory interpretation - 9th Edition - Justice G. P. Singh; State of Bihar v. Bihar Rajya m. S. E. S. K. K. Mahasangh, 2005 9 SCC 129 . ( 20 ) NORMALLY the use of a phrase by the legislature in a statutory provision like "not withstanding anything to the contrary contained in this Act" is equivalent to saying that the Act shall not be an impediment to the measure. Use of such expression is another way of saying that the provision in which the non-obstante clause occurs would wholly prevail over other provisions in the Act. Use of such expression is another way of saying that the provision in which the non-obstante clause occurs would wholly prevail over other provisions in the Act. Non-obstante clauses are to be regarded as clauses which remove all obstructions which might arise out of the provisions of any other law in the way of the operation of principal enacting provision to which the non-obstante clause is attached. Bihar Rajya M. S. E. K. K. , Mahasangam (9 supra); Iridiv India Telecom ltd. V. Motorola Inc, 2005 2 SCC 145 . ( 21 ) WHILE interpreting a provision containing a non- obstante clause it should first be ascertained what the enacting part of the section provides, on a fair construction of the words used according to their natural and ordinary meaning, and the non-obstante clause is to be understood as operating to set aside as no longer valid anything contained in the other provisions which is inconsistent with the section containing the non-obstante clause. Aswini Kumar v. Arabinda Bose, AIR 1952 SC 369 . A. V. Fernandez v. State of Kerala, AIR 1957 SC 657 . A clause beginning with the expression "notwithstanding anything contained in some particular provision in the Act" is more often than not appended to a section in the beginning with a view to give the enacting part of the section, in case of conflict, an overriding effect over the provision of the sections mentioned in the non obstante clause. It is equivalent to saying that in spite of the provision of the sections, mentioned in the non obstante clause, the enactment following it will have its full operation. (South India Corpn. (P) ltd. v. Secretary, Board of Revenue, Trivandrum, AIR 1964 SC 207 . ( 22 ) ON a natural and ordinary meaning being accorded and on a fair construction of the words used in the enacting part of Section 6-C it is clear that the rate of tax on packing material sold with the goods shall be the same as that of the goods packed or filled. As, in the present batch of cases, the rate of tax, on the rice sold to F. C. I, is 4% the same rate of tax of 4% shall be applicable to the gunnies sold along with the rice. As, in the present batch of cases, the rate of tax, on the rice sold to F. C. I, is 4% the same rate of tax of 4% shall be applicable to the gunnies sold along with the rice. Further, in view of the non-obstante clause contained therein, the enacting part of section 6-C shall, in the case of conflict, have an overriding effect over the provisions of Section 5 (1) of the APGST Act. ( 23 ) SINCE levy of tax on packing material, under Section 6-C, is notwithstanding anything contained in Sections, 5, 5-F, 6 and 6-A of the apgst Act, it is necessary to refer to those Sections also:-"5. Levy of tax on sales or purchases of goods: (1) Save as otherwise provided in this Act, every dealer shall pay a tax under this Act for each year on every rupee of his turnover of sales or purchases of goods in each year irrespective of the quantum of his turnover at the rates of tax and at the points of levy specified in the Schedules. (Sub-section (1) substituted for sub-sections (1) and (2) by Act No. 4 of 1989) (3) For the purpose of this section and the other provisions of this Act, the turnover which a dealer shall be liable to pay tax shall be determined after making such deductions from his total turnover, and in such manner as may be prescribed. (4) The taxes under this section shall be assessed, levied and collected in such manner, as may be prescribed: provided that- (i) in respect of the same transaction, the buyer or the seller but not both, as determined by such rules as may be prescribed, shall be taxed; (ii) where a dealer has been taxed in respect of the purchase of any goods, in accordance with the rules referred to in clause (i) of this proviso, he shall not be taxed again in respect of any sale of such goods effected by him. 5f. 5f. Levy of tax on transfer of property in goods involved in the execution of works contract: Notwithstanding anything contained in Section 5 or Section 6, every dealer shall pay a tax under this Act for each year, on his turnover of transfer of property in goods whether as goods or in some other form, involved in the execution of works contract, Provided that tax shall be paid at the rate of four paise on every rupee of his turnover pertaining to declared goods, if the goods have not suffered tax earlier, and no tax shall be payable on the turnover pertaining to declared goods, if such goods have suffered tax earlier under this act and are transferred from the contractor to the contractee in the same form in which they were purchased by the contractor: provided further that no tax shall be levied on the turnover of transfer of property in goods, specified in the Fourth Schedule to the Act, involved in the execution of works contract, if such goods are transferred from the contractor to the contractee in the same form in which they were purchased by the contractor: provided also that no such tax shall be leviable on the turnover of transfer of property in goods whether as goods or in some other form involved in the execution of works contract, if such transfer from the contractor to the contractee constitutes a sale in the course of inter-State trade or commerce under Section 3 or an outside the State sale under Section 4, or a sale in the course of import or export under Section 5 of the Central Sales Tax Act, 1956 but does not include the goods either obtained or purchased from other States and used in the execution of works contract: provided also that no tax shall be payable under this section on the turnover relating to the amounts paid to a sub-contractor as consideration for the execution of works contract whether wholly or partly subject to the production of proof that such sub-contractor is a registered dealer liable to tax under the Act and that the turnover of such amount is included in the return of turnover filed by such sub-contractor. 6. 6. Tax in respect of declared goods: Notwithstanding anything contained in Section 5, the sales or purchases of declared goods by a dealer shall be liable to tax at the rate, and only at the point of sale or purchase specified against each in the (Third Schedule on his turnover of such sales or purchases for each year) irrespective of the quantum of his turnover in such goods; and the tax shall be assessed, levied and collected in such manner as may be prescribed. [provided that where any such goods on which a tax has been so levied are sold in the course of inter-State trade or commerce, (and tax has been paid under the central Sales Tax Act, 1956, in respect of the sale of such goods in the course of inter-State trade or commerce the tax) so levied, (shall be reimbursed to the person making such sale in the course of inter-State trade or commerce,) in such manner and subject to such conditions as may be prescribed. ] (6-A Levy of tax on turnover relating to purchase of certain goods: every dealer, who in the course of business: (i) Purchases any goods (the sale or purchase of which liable to tax under this Act) from a registered dealer in circumstances in which no tax is payable under Section 5 or under section 6, as the case may be, or (ii) Purchases any goods (the sale or purchase of which is liable to tax under this Act) from a person other than a registered dealer, and (a) consumes such goods in the manufacture of other goods for sale or consumes them otherwise, or;) (b) disposes of such goods in any manner other than by way of sale in the State, or (c) dispatches them to a place outside the State except as a direct result of sale or purchase in the course of inter-State trade or commerce, shall pay tax on the turnover relating to purchase aforesaid at the same rate at which but for the existence of the aforementioned circumstances, the tax would have been leviable on such goods under Section 5 or Section 6" ( 24 ) SCHEDULES - TO BE READ AS AN EXTENSION OF THE SECTION IN the MAIN ACT: under Section 5 (1) of the APGST the tax payable by a dealer on his sales turnover shall be at the rates of tax and at the points of levy specified in the schedules. The Schedule is as much a part of the statute and is as much an enactment as any other part. ("craies on statute law" seventh Edition; "statutory interpretation: Second Edition: F. A. R. Bennion ). A schedule is an extension of the Section which induces it. Material is put in a schedule because it is too lengthy or detailed to be conveniently accommodated in a Section. It is often found convenient to incorporate part of the operative provisions of an Act in the form of a schedule. The Schedule is often used to hive off provisions which are too long or detailed to be put in the body of the Act. (Statutory interpretation: Second Edition: F. A. R. Bennion ). It is often found convenient to incorporate part of the operative provisions of an Act in the form of a schedule. The Schedule is often used to hive off provisions which are too long or detailed to be put in the body of the Act. (Statutory interpretation: Second Edition: F. A. R. Bennion ). To simplify the presentation of statutes it is the practise for their subject matters to be divided wherever appropriate between sections and schedules, the former setting out matters of principle and introducing the latter and the latter containing all matters of detail. This is purely a matter of arrangement and a Schedule is as much a part of the statute and as much an enactment as is the Section by which it is introduced. (Halsbury s Law of England 4th edition vol. 44 para 822 ). ( 25 ) EXPRESSION "notwithstanding" IN CONTRA DISTINCTION TO the PHRASE "save AS OTHERWISE PROVIDED" since the schedules are parts of the relevant Sections in the main enactment, the First Schedule to the A. P. G. S. T. Act must be held as part of Section 5. Section 5 (1) starts with the words "save as otherwise provided in the Act". The expression "save as otherwise provided by or under the Act" would mean, "save as otherwise expressly barred by or under the Act". State of Rajasthan v. Noor Mohd. , 1972 2 SCC 454 . It is a simple provision which merely subjects the provisions of the subject section to the provisions of the other Section. Where there is no clash, the phrase does nothing: if there is collision, the phrase shows that the other section is to prevail. The phrase provides no warranty of universal collision. Clark Ltd v. IRC, 1973 2 ALLER. ( 26 ) IT is well settled that the expression "notwithstanding" is in contradistinction to the phrase "subject to", the latter conveying the idea of a provision yielding place to another provision or other provisions to which it is made subject. ( 27 ) CHANDAVARKAR Sita Ratna Rao v. Ashalata S. Guram, 1986 4 SCC 447 . ( 26 ) IT is well settled that the expression "notwithstanding" is in contradistinction to the phrase "subject to", the latter conveying the idea of a provision yielding place to another provision or other provisions to which it is made subject. ( 27 ) CHANDAVARKAR Sita Ratna Rao v. Ashalata S. Guram, 1986 4 SCC 447 . Since both Sections 5 (1) and the First Schedule would apply, save as otherwise provided in Section 6-C, and the provisions of Section 6-C would apply, notwithstanding anything to the contrary in Sections 5 (1) and the first schedule, the conflict between Section 5 (1) read with the first schedule on the one hand and Section 6-C on the other, would necessitate (1) Section 6-C having full operation in spite of Sections 5 (1) and the First Schedule; and (2) Sections 5 (1) and the First Schedule yielding place to Section 6-C of the APGST Act. As a result, the rate of tax on gunnies shall be the same as that of the goods filled therein i. e. , rice, notwithstanding the prescription in Entry 19 (iii) (b) of the first schedule that its point of levy shall be at the point of first sale in the state. Absence of the words, specified in Sections 5 (5) of the Kerala General Sales Tax act or Section 5 (3-D) of the Karnataka General Sales Tax Act, is therefore of no consequence and the application of Section 6-C cannot be restricted only to the point of first sale within the State. ( 28 ) SRI V. Bhaskar Reddy, learned Counsel for the respondents, would submit that the scope of Section 6-C is limited only to cases where the first schedule prescribes different rates of tax for the goods and the packing material and in such a situation, in view of Section 6-C, the rate of tax applicable to the goods shall be the rate of tax applicable to the packing material. Learned Counsel would contend that the provisions of Section 6-C should be read in context and must be held not to affect the point of levy prescribed in the first Schedule. We express our inability to agree with this submission. Section 5 (1) specifically provides that the tax payable by a dealer shall be at the rates of tax and at the point of levy specified in the first schedule. We express our inability to agree with this submission. Section 5 (1) specifically provides that the tax payable by a dealer shall be at the rates of tax and at the point of levy specified in the first schedule. The non-obstante clause in Section 6-C is notwithstanding anything contained in Section 5 (1), (which would include the point of levy prescribed in the first Schedule ). Similarly Section 5 (1), (which would include the point of levy), is save as otherwise provided in section 6-C. Section 6-C would therefore apply notwithstanding the point of levy prescribed in the first Schedule. ( 29 ) SRI V. Bhaskar Reddy, Learned counsel for the respondents, would however, contend that such a construction would render the very prescription in Entry 19 (iii) (b) of the First Schedule redundant and that no provision of a Statute, much less a fiscal statute, can be read in such a manner. Would not accepting this submission, we ask ourselves, result in adding words in Section 6-C, to the effect that "it shall apply only at the point of levy specified in the Schedule", which construction is equally impermissible? Our answer is an emphatic yes. While different provisions of a taxing statute are to be harmoniously construed so as to give effect to all of them without reducing any part thereof redundant, it cannot, normally, go so far as to require words to be supplied to some of the provisions to bring about harmony. There is undoubtedly a conflict, and section 6-C, {in view of the non-obstante clause and the expression "save as otherwise provided" in Section 5 (1)}, must prevail over the point of sale prescribed in Entry 19 (iii) (b) of the First Schedule. ( 30 ) THE contention that Section 6-C is not a charging section cannot also be accepted. We are unable to appreciate the distinction sought to be made by Sri V. Bhaskar Reddy, learned counsel for the respondents, between Sections 5, 5b, 5c, 5f, 6 and 6a on the one hand and Section 6-C on the other. The expression "shall pay tax" used in Sections 5, 5b, 5c, 5f and 6a and "shall be liable to tax" used in Sections 6 are not dissimilar to the expression "tax shall be levied and collected" as used in Section 6c. The expression "shall pay tax" used in Sections 5, 5b, 5c, 5f and 6a and "shall be liable to tax" used in Sections 6 are not dissimilar to the expression "tax shall be levied and collected" as used in Section 6c. Further the heading of Section 5 is "levy of tax on sale or purchase of goods", that of Section 5a is "levy of tax on turnover", Section 5f is "levy of tax on transfer of property in goods involved in the execution of works contract", Section 6a is "levy of tax on turnover relating to purchase of certain goods" and 6-C is "levy of tax on packing material". Thus Sections 5, 5a, 5f, 6a and 6-C are provisions which relate to levy of tax. If sections 5 and 5a are to be held as charging sections we see no reason, in the absence of any discernible distinction, to hold that Section 6-C is hot. Sri V. Bhaskar Reddy, learned counsel for the respondents would urge, rightly so, that the interpretation placed by us on Section 6-C would result in gunnies being taxed at multiple points. If that is what the legislature intended, by providing a non-obstante clause in Section 6-C, and in subjecting Section 5 (1) to the other provisions of the APGST Act including Section 6-C, such a consequence would indeed be the result and must be accepted. ( 31 ) IT is also true, as contended by Sri V. Bhaskar Reddy, learned counsel for the respondents, that Entry 19 (iii) was inserted, in the First schedule, by Act 30 of 1997 w. e. f. 12-5-1997, after Section 6-C was amended, by Act 22 of 1995, w. e. f. 1-4-1995. As referred to supra, prior to 12-5-1997 "gunnies" were enumerated under Entry 157 of the First schedule and the point of levy then was also at the point of first sale in the state. The first schedule, when "gunnies" were under Entry 157 and now under Entry 19 (iii), details goods in respect of which single point tax is leviable under Section 5. While bringing "gunnies" under Entry 19 (iii) from entry 157 w. e. f. 12-5-1997, the State legislature did not choose to amend section 6-C or to omit the non-obstante clause therein. The first schedule, when "gunnies" were under Entry 157 and now under Entry 19 (iii), details goods in respect of which single point tax is leviable under Section 5. While bringing "gunnies" under Entry 19 (iii) from entry 157 w. e. f. 12-5-1997, the State legislature did not choose to amend section 6-C or to omit the non-obstante clause therein. By Act 30 of 1997 "gunnies" are now classified as two sub-entries under 19 (iii), "gunnies when sold without contents" under 19 (iii) (a) and "gunnies when sold with contents" under Entry 19 (iii) (b ). This sub-classification is obviously to bring gunnies, which are packing material, in tune with the requirements of section 6-C. Since the point of levy of tax on gunnies, both prior to its amendment, under Entry 157, and after the amendment w. e. f. 12-5-1997, under Entry 19 (iii), is at the point of first sale, nothing turns on its amendment by Act 30 of 1997, while interpreting Section 6-C of the APGST Act. Sri V. Bhaskar Reddy, learned counsel for the respondents, would submit that the interpretation placed on Section 6-C, by the Tribunal, is a possible interpretation beneficial to the tax payer, and should therefore be accepted. Learned Counsel would place reliance on the judgment in c. M. Francis (4 supra), wherein the Supreme Court held thus:"the courts in interpreting a taxing statute will not be justified in adding words thereto so as to make out some presumed object of the legislature. It is settled law that in case of doubt, that interpretation of a taxing statute, which is beneficial to the tax payer must be adopted" ( 32 ) IT is no doubt true that any ambiguity in the language of a provision in a tax/fiscal statute should be resolved in favour of the assessee. It is however well settled that where the language of the section is clear and no ambiguity arises, it is not for courts to create an ambiguity by interpretation as preliminary to the grant of relief to the tax payer to which he would not otherwise be entitled. General Commercial Corporation ltd. V. Commissioner of Income Tax, AIR 1955 Madras 64. CWT v. Kripa Shankar Dayashankar Worah, 1971 2 SCC 570 . General Commercial Corporation ltd. V. Commissioner of Income Tax, AIR 1955 Madras 64. CWT v. Kripa Shankar Dayashankar Worah, 1971 2 SCC 570 . HARDSHIP IS OF NO CONSEQUENCE WHILE INTERPRETING provisions OF A TAX STATUTE since the language of Section 6-C is plain and unambiguous, the provisions thereof must be enforced and it is, normally, not the concern of courts to examine its reasonableness or consider its consequences. In a taxing statute one has to look at what is clearly said. There is no equity about a tax. There is no intendment. There is no presumption as to a tax. Nothing is to be read in, nothing is to be implied. One can only look fairly on the language used cape Brandy Syndicate v. IRC, 1921 1 KB 64. If the meaning of the provision is reasonably clear, courts have no jurisdiction to mitigate harshness. ( 33 ) CANADIAN Eagle Oil Co. Ltd v. R, 1945 2 ALLER 499. IRC v. Ross and Coulter (Bladnock Distillery Co. Ltd ), 1948 1 ALLER 616. Lord Halsbury as early as 1901, in Cooke v. Charles A. Vogeler Co. , 1901 AC 102. stated the law:-"court of law, has nothing to do with the reasonableness or unreasonableness of a provision of a statute except so far as it may help it in interpreting what the legislature has said. If the language of a statute be plain, admitting of only one meaning, the legislature must be taken to have meant and intended what it has plainly expressed, and whatever it has in clear terms enacted must be enforced though it should lead to absurd or mischievous results. If the language of this sub-section be not controlled by some of the other provisions of the statute, it must, since its language is plain and unambiguous, be enforced, and your lordships House sitting judicially is not concerned with the question whether the policy it embodies is wise or unwise, or whether it leads to consequences just or unjust, beneficial or mischievous. "in Keshavji Ravji and Co. v. CIT, 1990 2 SCC 231 . the Supreme Court observed:"as long as there is no ambiguity in the statutory language resort to any interpretative process to unfold the legislative intent becomes impermissible. The supposed intention of the legislature cannot then be appealed to to whittle down the statutory language which is otherwise unambiguous. "in Keshavji Ravji and Co. v. CIT, 1990 2 SCC 231 . the Supreme Court observed:"as long as there is no ambiguity in the statutory language resort to any interpretative process to unfold the legislative intent becomes impermissible. The supposed intention of the legislature cannot then be appealed to to whittle down the statutory language which is otherwise unambiguous. If the intendment is not in the words used it is nowhere else. The need for interpretation arises when the words used in the statute are, on their own terms, ambivalent and do not manifest the intention of the legislature. Artificial and unduly latitudinarian rules of construction which, with their general tendency to give the taxpayer the breaks , are out of place where the legislation has a fiscal mission. " ( 34 ) AFTER referring with approval to the aforesaid judgments, the supreme Court in orissa State Warehousing Corporation v. CIT, 1999 4 SCC 197 . held thus:"be it noted that individual cases of hardship and injustice do not and cannot have any bearing for rejecting the natural construction by attributing normal meanings to the words used since "hard cases do not make bad laws in fine thus, a fiscal statute shall have to be interpreted on the basis of the language used therein and not dehors the same. No words ought to be added and only the language used ought to be considered so as to ascertain the proper meaning and intent of the legislation. The court is to ascribe natural and ordinary meaning to the words used by the legislature and the court ought not, under any circumstances, to substitute its own impression and ideas in place of the legislative intent as is available from a plain reading of the statutory provisions"we therefore hold that gunnies which have suffered tax within the state of A. P. can, under Section 6-C of the APGST Act, again be subjected to tax when sold along with its contents despite the prescription in Entry 19 (iii) of the first Schedule that Gunnies, sold with or without its contents, are liable to be taxed only at the point of first sale in the State. These batch of Tax Revision Cases are accordingly allowed and the order of the Sales Tax Appellate Tribunal set aside. There shall however be no order as to costs.