VidhiSangh

Supreme Court of India · 07/10/2025

M/S ARISTO PRINTERS PVT. LTD. versus COMMISSIONER OF TRADE TAX, LUCKNOW, U.P.

[2025] 10 S.C.R. 405 · 2025 INSC 1188

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Summary

The Supreme Court held that a printer of lottery tickets on customer-supplied paper is liable to trade tax under Section 3F(1)(b) of the U.P. Trade Tax Act, 1948 on the ink and processing chemicals it uses, because property in the diluted ink passes when it is applied to the paper. The question is whether property in goods was transferred in executing the works contract, not whether the goods were later consumed, and decisions treating consumption as excluding transfer proceeded on a wrong footing.

Issues

  1. Whether tax under Section 3F of the U.P. Trade Tax Act, 1948 can be levied on the ink and processing material used in printing lottery tickets under a works contract.
  2. Whether the fact that lottery tickets are actionable claims, excluded from the definition of goods, takes the printing outside Section 3F(1)(b).
  3. Whether goods consumed in executing a works contract can be the subject of a transfer of property in goods.

Provisions considered

Held

Result

Civil Appeal Nos. 703 and 705 of 2012 dismissed and the High Court's restoration of the levy on ink and processing material upheld; connected Civil Appeal Nos. 9189 and 8313 of 2015 de-tagged and directed to be listed for rehearing in November 2025.

Judgment PDF: Supreme Court of India, [2025] 10 S.C.R. 405.