{"id":50145,"date":"2001-08-24T00:00:00","date_gmt":"2001-08-23T18:30:00","guid":{"rendered":"https:\/\/www.legalindia.com\/judgments\/hind-spectron-manufacturing-pvt-vs-commercial-tax-officer-and-ors-on-24-august-2001"},"modified":"2017-10-23T20:23:33","modified_gmt":"2017-10-23T14:53:33","slug":"hind-spectron-manufacturing-pvt-vs-commercial-tax-officer-and-ors-on-24-august-2001","status":"publish","type":"post","link":"https:\/\/www.legalindia.com\/judgments\/hind-spectron-manufacturing-pvt-vs-commercial-tax-officer-and-ors-on-24-august-2001","title":{"rendered":"Hind Spectron Manufacturing Pvt. … vs Commercial Tax Officer And Ors. on 24 August, 2001"},"content":{"rendered":"
Calcutta High Court<\/div>\n
Hind Spectron Manufacturing Pvt. … vs Commercial Tax Officer And Ors. on 24 August, 2001<\/div>\n
Equivalent citations: (2001) 3 CALLT 524 HC<\/div>\n
Author: A Kabir<\/div>\n
Bench: A Kabir, A K Basu<\/div>\n<\/p>\n
<\/pre>\n
JUDGMENT<\/p>\n
  A. Kabir, J. <\/p>\n
 1. The short point involved in this writ petition which is directed against the order dated 7th November, 2000, passed by the West Bengal Taxation Tribunal in case No. R.N. 256 of 2000, is whether the declaration supplied to the petitioners in Form 12 could be used for transactions which apart from relating to the purchase of raw materials for manufacture of finished goods also related to purchase of packing materials, without payment of Sales Tax.\n<\/p>\n
 2. The petitioner No. 1 is a Private Limited Company and the petitioner No. 2 is one of its Directors. The petitioner company carries on business of manufacturing spices in powder form and selling the same in packets. The petitioner company had acquired Certificate of Registration, being Registration No. JB\/8198, under the West Bengal Sales Tax Act, 1994, and Rules. The said Registration Certificate refers to the petitioner as a manufacturing dealer of such spices in powder form.\n<\/p>\n
 3. According to the petitioner, powdered spices cannot be sold without being packed in containers which according to the petitioners is an essential part of the manufacturing process. It is the petitioners’ case that for the said purpose the petitioners purchased packing materials from various other registered dealers and Issued declaration in Form 12 to such selling dealers.\n<\/p>\n
 4. In the course of its business the petitioner company had applied to the Commercial Tax Officer, Jorabagan Charge, Calcutta, for issuance of such declaration Forms. The said authority, being the respondent No. 1, issued declaration forms to the petitioners pursuant to such application but by his order dated 5th June, 2000, he directed the petitioner company not to issue any declaration forms to cover the purchase of packing materials.\n<\/p>\n
 5. Being aggrieved by the said order the petitioner company made a representation to the said respondent on 22nd June, 2000, claiming that packing materials had been covered in the Registration Certificate Issued to the petitioner company and that it could, therefore, Issue declaration forms to the selling dealers for purchase of packing materials under Rule 52 of the West Bengal Sales Tax Rules, 1995.\n<\/p>\n
 6. Subsequently, the petitioners again applied for declaration forms to the respondent No. 1 mentioning that packing materials had been Included in the Registration Certificate of the petitioner company for manufacture of spices and the petitioner company was, therefore, entitled to get declaration forms for purchase of packing materials under Section 17(3)(a) (xi) of the above Act, read with Rule 52 of the aforesaid Rules, and also the conditions contained in column (c) (11) of Form 10, referred to in Rule 52. The respondent No. 1, however, while Issuing declaration forms directed the petitioner company by his order dated 11th September, 2000, not to use the said forms in connection with the purchase of packing materials.\n<\/p>\n
 7. Being aggrieved by the said direction given by the respondent No. 1, the petitioners herein filed an application before the West Bengal Taxation Tribunal under Section 8 of the West Bengal Taxation Tribunal Act, 1987, for setting aside the orders dated 5th June, 2000, and 11th September, 2000 to the extent the petitioner had been prohibited from using the declaration forms for purchase of packing materials. Inspite of noting that packing materials had been Included in the Registration Certificate issued to the petitioner company, the learned Tribunal held that packing materials were not intended to be used by the dealers directly in the manufacture of goods and for the sale of such goods. Interpreting the provisions of Section 17(2) of the West Bengal Sales Tax Act, 1994. the learned Tribunal, came to the conclusion that provision had been made to levy tax on the purchase of containers, although, nothing had been indicated therein regarding exemption of purchase of packing materials by SSI units.\n<\/p>\n
 8. Appearing in support of the writ application. Mr. Mihir Bhattacharya, learned advocate, submitted that having observed that packing materials had been included in the Registration Certificate Issued to the petitioner company. The learned Tribunal erred in thereafter holding that under Section 17(2) of the aforesaid Act tax could be levied on the purchase of containers.\n<\/p>\n
 9. Mr. Bhattacharya urged that since spices could not be sold unless the same properly sealed in packing materials must be held to be an
\nessential part or the manufacturing process as had been held in various decisions of different High Courts.\n<\/p>\n
 10. In support of his said submission Mr. Bhattacharya firstly referred to a Bench decision of the Delhi High Court in the case of Palam Potteries v. Commissioner of Sales Tax, reported in 45 STC Page 147, wherein the same question was considered and it was held that the petitioner as a manufacturer of crockery goods had to use packing materials for sale of the finished goods and, therefore, nails, packing strips and packing cases should be Included in the Registration Certificate of the petitioner.\n<\/p>\n
 11. Mr. Bhattacharya submitted that in the instant case packing materials had already been included in the Registration Certificate issued to the petitioner company.\n<\/p>\n
 12. Mr. Bhattacharya also referred to a single Bench decision of the Rajasthan High Court in the case of Commercial Tax Officer v. Mangi Ram Hart Ram,<\/a> reported in 67 STC Page 283, where the same question fell for consideration with regard to the manufacture and sale of snuff which was sold in containers. It was held in the said case that sale transaction related only to snuff which had been exempted from Sales Tax and which could not be sold without tin containers.\n<\/p>\n
 13. Mr. Bhattacharya then urged that the object of granting exemption from payment of Sales Tax was with the intention of encouraging the establishment of industrial units for the purpose of increasing the production of goods and promoting the development of industry in the State. Mr. Bhattacharya submitted that such incentive for promoting the economic growth and development provided in Taxing Statutes should be liberally construed so as to advance the object of the provision.\n<\/p>\n
 14. Mr. Bhattacharya submitted that in the instant case since the petitioner company was enjoying a tax holiday under Section 39, the provisions of Rule 52 of the West Bengal Sales Tax Rules are to be construed in a manner beneficial to the purchasing dealer in order to advance the object for grant of such holiday.\n<\/p>\n
 15. In support of his aforesaid submission Mr. Bhattacharya firstly referred to a decision of the Hon’ble Supreme Court in Commissioner of Sales Tax v. Industrial Coal Enterprises,<\/a> reported in 114 STC page 365, wherein in respect of manufacturing unit manufacturing coal briquettes, which had been granted exemption from payment of Sales Tax, it was observed that in Interpreting a Taxing Statute and the provisions relating to exemption, such interpretation must advance the purpose of such provisions.\n<\/p>\n
 16. Reference was also made to another decision of the Hon’ble Supreme Court in Commissioner of Income Tax, Amritsar v. Strawboard Manufacturing Company Ltd.,<\/a> reported in 177 ITR Page 431, where it was observed that it is necessary to remember that when a provision is made in the context of a law providing for concessional rates of tax for the purpose of encouraging an industrial activity, liberal construction should be put upon the language of the statute.\n<\/p>\n
 17. A similar view was expressed by the Hon’ble Supreme Court in Bajaj Tempo Limited v. Commissioner of Income Tax,<\/a> reported in 196 ITR Page 188. In relation to the establishment of new Industrial undertakings it was observed, that while interpreting a Taxing Statute where an incentive had
\nbeen given for growth and development, any restriction on exemption is to be construed in a manner so as to advance the objective regarding the incentive for growth and development and not to frustrate the same.\n<\/p>\n
 18. Mr. Bhattacharya lastly submitted that it was well-established that in relation to taxing statutes where two interpretations are possible the one favourable to the assessee should be preferred.\n<\/p>\n
 19. In support of his said submission Mr. Bhattacharya referred to the decisions of the Hon’ble Supreme Court in (1) Commissioner of Income Tax, West Bengal v. Vegetable Products Ltd.<\/a> (88 ITR Page 192) and (2) Mysore Minerals Ltd. v. Commissioner of Income Tax, Karnataka, Bangalore .\n<\/p>\n
 20. Mr. Bhattacharya submitted that the approach of the learned Tribunal to the question before it was completely erroneous and contrary to the established law and its decision was liable to be set aside.\n<\/p>\n
 21. Mrs. Seba Roy, learned advocate, who appeared for the Revenue, submitted that Section 39 of the West Bengal Sales Tax Act, 1994, read with Rule 52 of the West Bengal Sales Tax Rules 1995, did not provide for exemption in respect of packing materials and while a concession had been contemplated under Section 17(2)(b), no exemption had been provided for under Section 17(3)(a)(xi) of the aforesaid Act.\n<\/p>\n
 22. Mrs. Roy submitted that use of packing materials could not be said to be part of the manufacturing process of powdered spices for which the petitioner company had been enjoying tax holiday under Section 39 of the aforesaid Act and the inclusion of packing materials in the Registration Certificate of the petitioner company did not entitle it to use the declaration forms issued to it for the purpose of purchasing packing materials.\n<\/p>\n
 23. Mrs. Roy submitted that the views expressed by the learned Tribunal did not call for any interference and the instant application was liable to be dismissed.\n<\/p>\n
 24. From the submissions made on behalf of the respective parties the question which emerges for decision in this case is whether having regard to the provisions of Rule 52 of the West Bengal Sales Tax Rules, 1995, a selling dealer of packing materials is exempted from payment of tax on sales made to Industrial units enjoying tax holiday under Section 39 of the West Bengal Sales Tax Act, 1994. Or in other words, can declaration in Form 12 issued to the manufacturing unit be used for purchase of packing materials.\n<\/p>\n
 25. Rule 52 provides that the dealer selling goods, other than those specified in Part 8 of Schedule IV, to a registered dealer who is enjoying tax holiday, will be entitled to deduct under Section 17(3)(a)(xi) from his gross turnover of sales, that part of such gross turnover which represents such sales of goods to such registered dealers. Under the said provision the selling dealer has been given the benefit of tax exemption on sale of goods to a newly set up Industrial unit enjoying tax holiday. The proviso to Rule 52, however, provides that such deduction from the turnover in respect of a sale transaction shall not be permitted unless such goods are specified in the Certificate of Registration of the purchasing dealer as being intended for use by the dealer directly in the manufacture of goods for sale in West Bengal.\n<\/p>\n
 26. The learned Tribunal has construed the expression “directly in the manufacture of goods” as a restriction having been imposed in getting the
\nbenefit of exemption of tax on sale of packing materials to an SSI Unit. Such a view would be Justified if it is to be held that packing of manufactured goods for sale is not part of the manufacturing process.\n<\/p>\n
 27. There is little scope of argument that spices in powdered form cannot be marketed for sale unless they are properly packed tn suitable containers. The expression “directly in the manufacture of goods” and the expression “for sale in West Bengal” used in Rule 52 cannot, in our view, be read disjunctively, as has been done by the learned Tribunal. The expression have to be read in a manner so as to promote the object of the said Rule. One has to understand the satd expressions in the context that goods are being manufactured for sale and that the manufactured goods cannot be sold unless properly packed in suitable containers. It must, therefore, be held that packing materials are used directly in manufacture of goods and for sale thereof.\n<\/p>\n
 28. Similar is the view expressed by the Delhi High Court in the Palam Potteries case (supra) and by the Rajasthan High Court in Mangi Ram Hart Ram’s case (supra) cited by Mr. Bhattacharya.\n<\/p>\n
 29. Apart from the above, packing materials have been specifically Included in the Registration Certificate issued to the petitioner company. It does not, therefore, lie in the mouth of the Revenue to contend that declaration forms Issued to the petitioner company could not be used for purchase of packing materials. The Intention of the legislature to grant exemption to selling dealers of packing materials sold to registered dealers enjoying tax holiday under Section 39 of the 1994 Act is also evident from the wording of Clause (c) (ii) of Form 10 issued under Rule 52 of the 1995 Rules which categorically refer to containers and materials used for packing of goods manufactured for sale.\n<\/p>\n
 30. Even if for the sake of argument it is presumed that Rule 52 is capable of two Interpretations, in view of the settled principle that in taxing statutes where two views are possible the one favourable to the assessee should be adopted, the Court is to accept such interpretation which seeks to further the object of the Rule. In the instant case, the petitioner company is enjoying tax holiday under Section 39 of the 1994 Act. In our view, such tax holiday must cover not only goods manufactured for sale but the materials used for packaging such goods for sale. It must be held that a selling dealer has been given the benefit to tax exemption on sale of such packing materials to a newly set up Industrial unit enjoying tax holiday.\n<\/p>\n
 31. We are unable to agree with the learned Tribunal that the expression “directly in the manufacture of goods” used in the proviso to Rule 52, puts a restriction on a selling dealer from getting the benefit of tax exemption on sale of packing materials to an SSI Unit enjoying tax holiday. Such a view will defeat the purpose of grant of exemption from payment of tax to a newly set up Industrial unit with the object of encouraging and promoting Industry in the State. The said expression has to Include the expression “for sale in West Bengal” in order to give the provisions of Rule 52 a coherent and reasonable meaning. We are of the view that since packing materials are directly used in the manufacturing process, selling dealers of such materials will be exempted from payment of tax on sales to purchasing dealers, such as the petitioner company, enjoying tax holiday under Section 39 of the West Bengal Sales Tax Act, 1994.\n<\/p>\n
 32. We, therefore, set aside the order passed by the learned Tribunal on 7th November, 2000, and allow the instant writ application.\n<\/p>\n
The two orders issued by the Respondent No. 1 on 5th June, 2000 and 11th September, 2000, directing the petitioner company not to use the declaration in Form 12 for purchase of packing materials for packing of spices in powdered form, are hereby quashed.\n<\/p>\n
 There will be no order as to costs.\n<\/p>\n
 All parties to act on a signed copy of the operative part of this judgment on the usual undertakings.\n<\/p>\n
 Stay as prayed for in considered and refused having regard to the views expressed by us in the Judgment.\n<\/p>\n
  A.K. Basu, J.\n<\/p>\n
 33. I agree.\n<\/p>\n
 34. Petition allowed <\/p>\n","protected":false},"excerpt":{"rendered":"
Calcutta High Court Hind Spectron Manufacturing Pvt. … vs Commercial Tax Officer And Ors. on 24 August, 2001 Equivalent citations: (2001) 3 CALLT 524 HC Author: A Kabir Bench: A Kabir, A K Basu JUDGMENT A. Kabir, J. 1. The short point involved in this writ petition which is directed against the order dated 7th […]<\/p>\n","protected":false},"author":1,"featured_media":0,"comment_status":"open","ping_status":"open","sticky":false,"template":"","format":"standard","meta":{"_lmt_disableupdate":"","_lmt_disable":"","_jetpack_memberships_contains_paid_content":false,"footnotes":""},"categories":[22,8],"tags":[],"class_list":["post-50145","post","type-post","status-publish","format-standard","hentry","category-calcutta-high-court","category-high-court"],"yoast_head":"\nHind Spectron Manufacturing Pvt. ... vs Commercial Tax Officer And Ors. on 24 August, 2001 - Free Judgements of Supreme Court & High Court | Legal India<\/title>\n<meta name=\"robots\" content=\"index, follow, max-snippet:-1, max-image-preview:large, max-video-preview:-1\" \/>\n<link rel=\"canonical\" href=\"https:\/\/www.legalindia.com\/judgments\/hind-spectron-manufacturing-pvt-vs-commercial-tax-officer-and-ors-on-24-august-2001\" \/>\n<meta property=\"og:locale\" content=\"en_US\" \/>\n<meta property=\"og:type\" content=\"article\" \/>\n<meta property=\"og:title\" content=\"Hind Spectron Manufacturing Pvt. ... vs Commercial Tax Officer And Ors. on 24 August, 2001 - 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