( 1 ) THESE Tax Revision Cases have been referred for the decision of the Full Bench by Mohamed Ahmed Ansari, J. (as he then was), and Jaganmohan Reddy, J.

( 2 ) THE question for decision in these cases is whether the price of the materials used for packing re-dried tobacco is liable to be included in the taxable turnover of the assessees.

( 3 ) THE petitioners, who are hereinafter refer red to as "the assessees", are a private limited company registered under the provisions of the Indian Companies Act, having their place of business in Guntur town. They have a plant for redrying raw tobacco, which is a process designed to create suitable conditions for the proper manuring of the leaf,

( 4 ) FOR a proper appreciation of the contentions raised before us, it is necessary to understand the nature and purpose of what is, in common parlance, known as the redrying process. After the grading and stripping operations are over, the leaf is reconditioned or redried. For the purpose all the leading exporters and cigarette manufacturers use the re-ordering or re-conditioning plant. This plant consists of a series of three chambers in each of which the heat and humidity are regulated. T