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Civil · Reportable judgment

M/s Aristo Printers Pvt. Ltd. vs Commissioner of Trade Tax, Lucknow, U.P.

Court
Supreme Court of India
Date
7 October 2025
Case No.
Civil Appeal No. 703 of 2012
Result
Disposed
Bench
J.B. Pardiwala, K.V. Viswanathan
Citation
[2025] 10 S.C.R. 405 : 2025 INSC 1188
Acts & Sections
Uttar Pradesh Trade Tax Act, 1948 Central Sales Tax Act, 1956 Constitution
Supreme Court Reports [2025] 10 S.C.R. 405 : 2025 INSC 1188
Issue for consideration
Issue arose whether tax can be levied u/s.3F of the Uttar Pradesh Trade Tax Act, 1948, on the ink and processing material used by the appellant in undertaking the printing work of lottery tickets.
Headnote

Uttar Pradesh Trade Tax Act, 1948 – ss.2(m), 3F – Works contract – Tax on the right to use any goods or goods involved in the execution of works contract – Appellant undertaking the printing work of lottery tickets – Levy of trade tax u/s.3F on the ink, chemical and processing material used by the appellant – Tribunal deleted the tax on the value of ink and other processing materials, including chemicals – However, the High Court set aside the order passed by the tribunal – Correctness:

Held: Appellant liable to pay tax u/s.3F(1)(b) on the ink and processing material – All three conditions required to sustain a levy of tax u/s.3F(1)(b) are fulfilled: works contract exists for printing of lottery tickets; ink and chemicals have been involved in the execution of the works contract; and the property in the ink and chemicals has been transferred in execution of the works contract – Appellant has admitted that the contract for printing lottery tickets is a works contract – It is clear that the ink, chemical and other processing material were involved in the printing of the lottery tickets – There is a transfer of property in the ink and chemicals used in the printing of the lottery tickets – Works contract is for the printing of lottery tickets, and “the works” refers to the final, tangible printed ticket – Taxable event, or the “deemed sale”, occurs at the precise moment the ink is applied to the paper – This act constitutes “incorporation in the works”, as the ink and the chemicals (with which the ink is mixed) are involved in the execution of the work contract and become a part of the lottery ticket – In this process, there is a tangible transfer of the diluted ink, a composite good comprising both the ink and the processing chemicals – Transfer of ink and chemicals in their chemically altered form constitutes a valid transfer of property – Thus, since it is impossible to transfer the ink without also transferring the chemicals it is diluted with, it can be conclusively inferred that the property in both the ink and the chemicals has been transferred. [Paras 66-73]

Keywords: Tax · Ink and processing material used in undertaking the printing work · Works contract · Tax on the right to use any goods or goods involved in the execution of works contract · Printing work of lottery tickets · Levy of trade tax · Works contract for printing of lottery tickets · Transfer of property in the ink and chemicals used in the printing of the lottery tickets · The works · Deemed sale · Incorporation in the works

As published in the Supreme Court Reports, Supreme Court of India. Headnotes prepared by: Nidhi Jain. Text from the Indian Supreme Court Judgments open data set (Dattam Labs), CC BY 4.0.

Full Judgment Text

Judgment J.B. Pardiwala, J. For the convenience of exposition, this judgment is divided into the following parts: INDEX* A. FACTUAL MATRIX .............................................................. B. SUBMISSIONS ON BEHALF OF THE PARTIES .............. (i) Submissions on behalf of the Appellant ........................ (ii) Submissions on behalf of the Respondent ................... C. ISSUE TO BE DETERMINED ............................................. D. ANALYSIS ............................................................................ (i) Relevant provisions under the Act,
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