JUDGMENT

[WP(C) Nos.9172/2014, 20522/2015, 482/2021, 4541/2021, 4271/2022]

The issues raised in these Writ Petitions appear to be covered in favour of the petitioners by the order of the Supreme Court in SLP(C) Nos.16551-16555 of 2012 and connected cases. The Supreme Court, while considering the correctness of the judgment of the Andhra Pradesh High Court reported in State of Andhra Pradesh v. Bharat Sanchar Nigam Ltd. [(2012) 49 VST 98] held as follows:

“In the present case, the High Court held that SIM Cards, Rechargeable Coupons, Fixed Monthly Charges and Value-Added Services (towards SMS, ring tones, and download music etc.) are not "goods". It relied upon not only the judgment in "Idea Mobile Communication" but also the judgments of this Court in Bharat Sanchar Nigam Ltd. vs. Union of India [2006 (2) SCR 823] , Associated Cement Companies Ltd. VS. Commissioner of Customs [2001 (1) SCR 608] and Tata Consultancy Services vs. State of A.P. " (relied upon by the revenue).

The High Court, however, remitted the matter for consideration for ascertainment of facts relating to lev