1. In all these appeals, the question raised relates to the competence of the State to levy Sales Tax/VAT on telecommunication service, interpretation of constitutional and statutory provisions and upholding the rule of law. Therefore, they are taken up for consideration together and disposed off by this common order.

2. For the purpose of clarity, the facts pleaded by appellants/petitioners in each of these cases are set out in brief.

FACTUAL MATRIX

W.A.Nos.654/2011, 817-828/2011, 789/2011, 790/2011, 805-816/2011, 792-803/2011, 791/2011 and 829-840/2011.

3. The appellant in all these appeals – M/s. Bharath Sanchar Nigam Limited (for short herein after referred to as the ‘BSNL’) is wholly owned Government of India undertaking providing all types of telecom services in the country except the metro cities of Delhi and Mumbai. It is the successor and assign of the erstwhile Department of Telecom. Ministry of Communication and IT (Government of India). The BSNL as a Service Provider merely facilitates its subscribers in transmission of their voice or data in its network. The transmission facilitation services are provided by using different medium of transmission depending upo