STATE OF PUNJAB & ANR. vs M/S. BAJAJ ELECTRICALS LTD.

The Supreme Court held that under Section 3 of the Punjab Professions, Trades, Callings and Employments Taxation Act, 1956, the respondent, a Joint Stock Company with no physical presence in Punjab, was not liable for profession tax as its activities constituted mere ancillary operations rather than carrying on trade within the State. The Court defined 'trade' as the exchange of goods for money or goods, emphasizing that the determination of whether trade is conducted at a location involves assessing the nature of the activities and relevant facts. The High Court's decision to quash the tax assessment was upheld.