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M/S Xerox Modicorp Limited vs State Of Karnataka on 24 August, 2005

5. Per contra, Shri K. Vinod Chandran, learned special Government Pleader would press for our acceptance the principle ST.REV.NOS.30 & 69/2004 10 "quicquid plantatur solo, solo cedit". He would also submit that this is a case where, even going by the version of the petitioner, property in the chemical is transferred to the Awarder, the moment it is put into the effluent. The fact that it is subsequently consumed, would not absolve the petitioner of his liability to pay tax, as there is a transfer of property in the goods, as there is delivery of the chemical before it is consumed. He would also point out that the version of the petitioner which we have extracted, would show that he has obtained the various chemicals from the effluent which are discharged from the Travancore Titanium Products. No doubt, there is an addition of the required dosage of lime. He would submit that it cannot be in the region of any doubt that the chemical in question is goods, within the meaning of the Act and since the only contention of the petitioner is that there is no transfer of the said goods, the matter is covered by the Judgment of the Apex Court in Xerox Modicorp Ltd. v. State of Karnataka ((2005) 142 STC 209). We shall refer to the ST.REV.NOS.30 & 69/2004 11 said decision in greater detail as much turns on the applicability of the principle enunciated therein to the facts of this case.
Supreme Court of India Cites 5 - Cited by 11 - S N Variava - Full Document

Gannon Daunkerley & Co. & Ors vs State Of Rajasthan & Ors on 17 November, 1992

We would think, it may not be possible. Therefore we would be justified in holding that the effluent and the treated effluent both belonged to the awarder. It is, therefore, into the ST.REV.NOS.30 & 69/2004 43 property of the awarder, namely the effluent that the assessee supplies the chemical. The Apex Court in its decision in Gannon Dunkerley & Co. & Others v. State of Rajasthan & Others ((1993) 1 SCC 364) had, inter alia, held that cost of consumables, such as, water, electricity, fuel etc. used in the execution of the works contract, the property in which is not transferred in the course of execution of a works contract, is to be deducted. In Section 5C also, the words "not involving any transfer of property in goods"
Supreme Court of India Cites 55 - Cited by 253 - S C Agrawal - Full Document

Builders Association Of India & Ors. ... vs Union Of India & Ors. Etc. Etc on 31 March, 1989

"2. A bare perusal of the above Explanation is sufficient to show that transfer of property in goods (whether as goods or in some other form) is the sine qua non for its application. The mere execution of a works contract does not by itself attract liability for tax under the Act unless it is accompanied by transfer of property in goods, involved in the execution of the contract. The emphasis is on the transfer of property in goods - Builders Association of India v. Union of India (1989) 73 STC 370 (SC) at page 396. When goods used in the process of executing a works contract are consumed in the process, as in the case of the chemicals used by the petitioner or fuel and ST.REV.NOS.30 & 69/2004 20 power, there is no transfer of any goods from the contractor to the awarder of the contract attracting liability to tax.
Supreme Court of India Cites 40 - Cited by 303 - M Rangnath - Full Document
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