COMMISSIONER OF SALES TAX, MADHYA PRADESH,INDORE vs MADHYA PRADESH ELECTRICITY BOARD, JABALPUR

The Supreme Court held that the Electricity Board, under the Electricity Supply Act, 1948, is a 'dealer' as it sells and distributes electric energy, which qualifies as 'goods' under the C.P. & Bearar Sales Tax Act, 1947 and the Madhya Pradesh General Sales Tax Act, 1959. The Court clarified that electric energy, despite being intangible, possesses attributes of movable property, thus falling within the broad definition of 'goods'. The High Court's ruling that electricity is not 'goods' and the supply of steam is not taxable was overturned, affirming the Board's liability for sales tax on electricity supply.