RAMACHANDRA IYER, J.

These two revision cases raise the question of liability to sales tax of turnovers representing the price of packing materials employed for effecting sales of the cotton and yarn respectively by the assessees in the two cases. The question whether the turnover relating to packing materials would be assessable to tax, there being no claim for exemption under rule 5(1)(g)(ii) of the Sales Tax (Turnover and Assessment) Rules, was considered in two decisions of this Court, viz., Varasukhi and Co. v. Province of Madras and Indian Leaf Tobacco Development Co., Ltd. v. State of Madras It was held that where there was a sale of certain goods, the intention being to sell the goods as packed, there would be a sale of the packing materials as well and the turnover relating to them would be liable to sales tax.

Mr. Sethuraman, who appeared for the assessee, contended that the two decisions required reconsideration in the light of the judgment of the Supreme Court in State of Madras v. Gannon Dunkerley and Co., Ltd. We do not agree that decisions in the two cases are in any way contradictory to the principles laid down by the Supreme Court. In State of Madras v. G