( 1 ). In this case the respondent manufactures writing paper. He also manufactures the wrapping paper, which is utilised for wrapping the writing papers sold by him. There is no dispute that the wrapping paper which is utilised in wrapping writing papers for sale in the wholesale market will have to be included in the value of the goods. This point is put beyond any doubt by the judgment of this court in the case of CCE v. Ponds India Ltd. Sabyasachi Mukharji, J. (as His Lordship then was), expressed the view:

"in my opinion, the views expressed by the majority of the judges in Godfrey Philips case were in consonance with the views of 66 this court in the Bombay Tyre International case. The question is not for what purpose a particular kind of packing is done but the test is whether a particular packing is done in order to put the goods in the condition in which they are generally sold in the wholesale market at the factory gate and if they are generally sold in the wholesale market at the factory gate in certain packed condition, whatever may be the reason for such packing, the cost of such packing would be includible in the value of the goods for assessment to excise duty. "his L