M/S. Rainbow Colour Lab & Anr vs The State Of Madhya Pradesh & Ors

The Supreme Court examined whether the services rendered by photographers in taking, developing, and printing photographs constitute a works contract under Article 366(2A)(b) of the Constitution and Section 2(n) of the M.P. General Sales Tax Act. The Court upheld the High Court's ruling that the work done by photographers is primarily a service contract involving skill and labor, rather than a sale of goods, thus exempting them from sales tax. The judgment reaffirmed the legal position established in Assistant Sales Tax Officer & Ors. vs. B.C. Kame, stating that the 46th Constitutional Amendment did not alter this interpretation significantly.