(1.) These are petitions under S.15-B of the General Sales Tax Act, 1125. They seek a revision of the orders of the Sales Tax Appellate Tribunal, Trivandrum, in Appeal
(2.) The question for determination in both the cases is whether when bags of rice are sold the gunny bags concerned attract sales tax under the General Sales Tax Act, 1125. The Tribunal has held that the tax is attracted and it is the correctness of that decision that is challenged before us.
(3.) It is not disputed that the rice itself does not attract any tax under the Act. S.5 (vi) of the Act specifically provides that the sale of food grains shall be exempt from taxation.