KANAKARAJ, J.

The assessee in all the tax cases is the same, but they relate to three assessment years, viz., 1973-74, 1974-75 and 1975-76. In all the assessment years, the assessee is seeking to exclude from the taxable turnover, packing charges, labour charges and excise duty. So far as excise duty is concerned it relates only to the year 1975-76, and the inclusion of the same is not seriously disputed by the learned counsel for the petitioner. Accordingly, we omit to consider the claim relating to excise duty.

2. The assessing authority held that packing charges and the labour charges for packing were eligible for exemption under a Notification G.O.Ms. No. 3291, Revenue, dated October 1, 1960 only up to January 30, 1974. Therefore in the assessment year 1973-74 he had included the turnover under these headings for the period from January 30, 1974 to March 31, 1974. The assessing authority held that packing charges and labour charges for packing would certainly attract liability because these charges are incurred by the dealers in respect of goods sold at the time or before the delivery thereof. He therefore held that these charges properly formed part of the sale price