(1.) This tax case (revision), filed by the assessee as against the order of the Tamil Nadu Sales Tax Appellate Tribunal relating to the assessment year 1993-94, was admitted by this court on the following substantial questions of law:
(2.) Aggrieved by this, the assessee went on appeal before the Appellate Assistant Commissioner, who agreed with the assessing officer and viewed that polythene films purchased were not actually packing materials as such and section 3(3) contemplated packing materials directly used for packing manufactured item. As it had undergone a process as a sachet, section 3(3) was not available. Consequently, the assessee was not entitled to the concessional levy.
(3.) Thus, on this ground, the claim was rejected. Aggrieved by this, the assessee went on further appeal before the Tamil Nadu Sales Tax Appellate Tribunal, which confirmed the view of the authorities below.