CHANDRA REDDY, C.J.

The controversy that is raised in this appeal filed by the State Government against the judgment of our learned brother, Veeraswami, J., relates to the scope and ambit of the notification dated 28th February, 1955. By and under that notification, potatoes among other goods were exempted from the payment of sales tax. The respondent who is a dealer in the potatoes submitted returns for the year 1958-59, disclosing a gross turnover of Rs. 7, 36, 333.20 and claiming a deduction on a turnover of Rs. 7, 21, 454.52 as representing inter-State sales of potatoes. The balance of Rs. 14, 878.68, being the value of packing material, was shown as assessable turnover. The break-up of this figure of Rs. 14, 878.68 was as follows : Rs. 11, 239.87 as the price of gunnies sold prior to 1st October, 1958, and taxable at 2 per cent., and Rs. 3, 638.81, being the cost of the packing material sold subsequent to 1st October, 1958, and taxable at 7 per cent. On checking the accounts, the assessing authority thought that the value of gunnies sold before and after 1st October, 1958, should be computed at Rs. 15, 491.25 and Rs. 4, 851.75 respectively. He, therefore, issued a n