K. S. PARIPOORNAN, J. - The same assessee is the revision-petitioner in this batch of three cases. The assessee is a private limited company registered as small-scale industrial unit. It bottles and sells Indian-made foreign liquor. The bottles containing liquor are packed in cardboard cartons. The bottled liquor is cleared by the Excise in its packed form. The controversy mooted in this batch of three cases, relating to the assessment years 1981-82, 1982-83 and 1983-84, is that the value of cardboard cartons charged for separately in the invoices, used in the packing of liquor bottles, should have been exempted and the turnover relating thereto should not have been included in the taxable turnover. This plea was negatived by the assessing authority. The assessments for the three years (1981-82, 1982-83 and 1983-84) were confirmed by the first appellate authority and the Sales Tax Appellate Tribunal. It is thereafter, the assessee has come up in revisions.

2. We heard counsel for the revision-petitioner, Mr. K. C. Balagangadharan, as also counsel for the Revenue, Special Government Pleader (Taxes), Shri N. N. D. Pillai. It was urged that the assessee used to purchase the c