ORDER : (T. Vinod Kumar, J.) Since the revision petitioner and the lis involved in all these revision cases is one and the same, they are being disposed of by this Common Order. 2. These Tax Revision Case are directed against the orders of the Sales Tax Appellate Tribunal (for short ‘the Tribunal’), passed under the provisions of CST Act, 1956 (for short ‘the Act’). The case details are as follows: TREVC. No. Date of order of Tribunal Appeal No. before the Tribunal Assessment Year 122/2004 15.09.2000 TA.No.1019/1996 1988-89 124/2004 18.09.2000 TA.No.1020/1996 1990-91 125/2004 04.10.2000 TA.No.1022/1996 1992-93 126/2004 22.09.2000 TA.No.1021/1996 1991-92 3. Heard learned counsel for the petitioner, learned Special Standing Counsel appearing on behalf of respondent-State, in all the revisions, and perused the record. 4. The case of the revision petitioner is that it is a Government of India undertaking, manufacturing cement at its plant in Tandur, Ranga Reddy District, and is registered on the rolls of Commercial Tax Officer, Rajendranagar, Ranga Reddy District. 5. Since the issue involved in all the revisions is one and the same, the discussion is made in relation to TREVC.No.125 of 2004. TREVC.No.125 of 2004 6. The revision petitioner contends that during the assessment year 1992-93, it had received an order for supply of cement from Bangalore Water Supply and Sewerage Board, Bangalore; that in order to comply with the aforesaid order, it had supplied the cement from its units situated at Yerraguntla of Cuddapah District and Tandur of Ranga Reddy District; that against the aforesaid supplies made by the revision petitioner from its aforementioned units, the recipient viz., Bangalore Water Supply and Sewerage Board, Bangalore, had issued (03) C-Declaration Forms covering the supplies made by it from both the units; that the revision petitioner had submitted all the 3 C- Declaration Forms to its Assessing Authority at Yerraguntla and obtained certificate covering the supplies made from its Tandur Unit included in the C-Declaration forms submitted by the revision petitioner’s Yerraguntla Unit along with certified Xerox copies of all the C-Declaration forms; and that on the revision petitioner filing the aforesaid declarations, the Assessing Authority had granted the benefit of concessional rate of tax covering supplies made from Tandur Unit. 7. 7. The petitioner further contends that the revisional authority in exercise of revisional powers, had revised the order of assessment, whereby the benefit of concessional rate of tax as extended on the basis of the Xerox copies of C-Declaration forms as certified by the Assessing Authority of the petitioner’s unit at Yerraguntla, was withdrawn and the turnover relating to interstate sales of cement to the tune of Rs.1,09,00,131/- was assessed to tax at higher rate, as not covered by declaration forms. 8. The revisional authority also further levied tax on HDPE woven sacks, in which the cement is packed and sold by the revision petitioner at the rate of tax applicable to cement. 9. Aggrieved by the aforesaid order passed by the revisional authority, the petitioner herein had filed appeal before the Tribunal vide TA.No.1022/1996. 10. The Tribunal, insofar as levy of tax on HDPE woven sacks(HDPE bags) at the rate of the contents i.e., cement is concerned, by applying the ratio laid down by the Apex Court in the case of Raj Sheel v. State of Andhra Pradesh, 1989(74) STC 379 (SC) had held that the conditions laid down by the Apex Court would apply insofar as sale of cement by the appellant is concerned and accordingly, dismissed the appeal filed by the petitioner in relation to levy of tax on HDPE Woven Sacks at the rate as applicable to the cement. 11. Insofar as interstate supplies of cement made to Bangalore Water Supply and Sewerage Board, Bangalore, for which the revision petitioner was required to furnish C- Declaration Forms to the Assessing Authority in order to claim the benefit of concessional rate of tax, had observed that concessional rate of tax cannot be granted on the basis of Xerox copies, since the CST enactment does not provide for such benefit being extended on submission of Xerox copies, and that the submission of statutory forms in Original is a mandatory requirement under the enactment to claim such relief. 12. By holding as above, the Tribunal dismissed the appeal preferred by the revision petitioner on the aforesaid count also. 13. Aggrieved by the aforesaid order of the Tribunal, the revisional petitioner has filed the present Revision. 14. 12. By holding as above, the Tribunal dismissed the appeal preferred by the revision petitioner on the aforesaid count also. 13. Aggrieved by the aforesaid order of the Tribunal, the revisional petitioner has filed the present Revision. 14. On behalf of the revision petitioner it is contended that the Tribunal had failed to notice that the revision petitioner having obtained (03) C-Declaration Forms covering the supplies of cement made to Bangalore Water Supply and Sewerage Board, Bangalore, from its two units namely Yerraguntla and Tandur, could procure the C-Declaration Forms against one single purchase order and produce the same at one place; that the concerned Assessing Authority, before whom the said C- Declaration Forms are filed, having certified the Xerox copies thereof insofar as the supplies affected from the revision petitioner’s units at Tandur, it is entitled to claim benefit of concessional rate of tax on such supplies; and thus, the revisional authority as well as the Tribunal had erred in rejecting the claim of concessional rate of tax on such supplies. 15. On behalf of the revision petitioner it is also contended that since, HDPE Woven Sacks are reusable packing material, the same are liable to be taxed at the rate as applicable to such products under the provisions of APGST Act, 1957, and cannot be subjected to tax at the rate of contents as was done by the revisional authority and confirmed by the Tribunal, and thus, prayed to allow this revision. 16. We have taken note of the respective contentions urged. 17. In order to appreciate the submissions made on behalf of the revision petitioner with regard to C-Declaration Forms, it is necessary to refer to the provisions of CST Act, 1956. 18. Section 6 of the CST Act, 1956 deals with liability to tax on interstate sales and Section 8(4) of the said Act provides for the rate of tax on sales in the course of interstate trade or commerce being subjected to concessional rate of tax @ 4%, if a declaration duly filled and signed by the registered dealer, to whom goods are sold containing the prescribed particulars in a prescribed form obtained from the prescribed authority, is furnished within the prescribed time or within such time as that authority may for sufficient cause permit. 19. 19. The Declaration contemplated under Section 8(4) of the CST Act, is form-C Declaration as prescribed under CST(R&T) Rules (for short ‘the Rules’). 20. A conjoint reading of Section 6 with Section 8(1) & (4) read with Rule 12 of the CST Rules makes it clear that the dealer selling goods in order to claim benefit of concessional rate of tax is required to obtain C-Declaration forms in original containing the details of supplies made against the purchase order by obtaining the same from the purchasing dealer’s Assessing Authority. 21. Though the revision petitioner had claimed of the purchasing dealer’s Assessing Authority having issued a single Declaration (3 in all) covering the supplies of cement made from revision petitioner’s Yerraguntla Unit as well as Tandur Unit, and the original of such declarations having been filed with the Assessing Authority of Yerraguntla Unit, and the said assessing authority having issued certificate along with certified Xerox copies of such declarations, the said certified Xerox copies cannot be equated as complying with the mandatory requirement prescribed under the CST Act and the Rules made thereunder.[See: Delhi Automobiles (P) Ltd. v. Commissioner of Sales Tax, Delhi, (1997) 10 SCC 486 = (1997) 104 STC 75 and Commissioner of Sales Tax, M.P., Indoor v. Gajanan Bidi Leaves Co., (1985) SCC Online MP 149 = (1986) 62 STC 203 ]. 22. The revision petitioner at least on noticing that the C- Declaration forms issued by the purchasing dealer are covering the supplies made by it from its units situated at Yerraguntla and Tandur, ought to have taken steps to get the same rectified by obtaining C-Declaration forms in respect of each supplies made from each of its unit, separately. 23. 22. The revision petitioner at least on noticing that the C- Declaration forms issued by the purchasing dealer are covering the supplies made by it from its units situated at Yerraguntla and Tandur, ought to have taken steps to get the same rectified by obtaining C-Declaration forms in respect of each supplies made from each of its unit, separately. 23. Further, the revisional authority having noted that the revision petitioner having filed duplicate copy of the C-Form, pertaining to Tandur Unit with the CTO’s office, Yerraguntla, the claim of the revision petitioner of the buyer having issued one C-Form for the supplies made from its Yerraguntla and Tandur Units and the original C-forms having been submitted to the CTO’s Office at Yerraguntla Unit, clearly goes to show that the assessee is camouflaging the transaction to avoid tax and the said Xerox copies of (03) C-Declaration Forms cannot be accepted as valid, the said finding recorded by the revisional authority as confirmed by the Tribunal being a finding of fact, in the considered view of this Court cannot be considered as giving rise to question of law, and thus, the claim of the revision petitioner on this count is rejected. 24. Insofar as next contention of the revision petitioner that HDPE woven sacks being liable to tax under Entry 19 of Schedule-I and such sale being not covered by the provisions of Section 6C of the APGST Act is concerned, it is to be noted that the issue is no longer res integra in view of the decision of the Apex Court in Raj Sheel ’s case(1 supra) . 25. Further, Section 6C of the APGST Act at the relevant point reads as under : “where goods packed in any material or sold or purchased the material, in which 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 material at the rate of tax, if any, as applicable to sale or as the case may be, purchase of goods, themselves”. 26. Though on behalf of the revision petitioner, it is contended that since, HDFE woven sacks are reusable, the test that is required to be applied in such cases has been set-out by the Apex Court in Raj Sheel ’s case(1 supra). 27. 26. Though on behalf of the revision petitioner, it is contended that since, HDFE woven sacks are reusable, the test that is required to be applied in such cases has been set-out by the Apex Court in Raj Sheel ’s case(1 supra). 27. By applying the test laid down by the Apex Court to the facts of the present case, it is to be noted that the revision petitioner is not dealing in sale and purchase of HDPE bags and is not a registered dealer to deal in sale and purchase of HDPE woven sacks. Since, the revision petitioner has used HDPE woven sacks for packing the cement for being sold, it cannot be said that there is an implied agreement to sell cement and HDPE woven sacks, separately, for it not to be subjected to tax under the provisions of Section 6C and on the other hand, liable to be taxed as independent container liable to tax at the rate applicable to such containers under Schedule-I of the APGST Act. 28. Thus, considered from any angle, the revision petitioner cannot claim that the order of the Tribunal dismissing the appeal preferred by the revision petitioner against the order of the revisional authority suffers from error or giving rise to any question of law, for it to be considered by this Court, in exercise of revisional jurisdiction under Section 22 of the APGST Act. 29. Thus, the TREVC.No.125 of 2004 is devoid of merit and is accordingly, dismissed. No order as to costs. TREVC. Nos.122, 124 & 126 of 2004 30. In view of the discussion made in TREVC.No.125 of 2004 and for the reasons as were stated therein, these TREVCs also fail and are accordingly, dismissed. No order as to costs. 31. Consequently, miscellaneous petitions pending, if any, shall stand closed in the light of this final order.