Profit motive remains essential for business under sales tax law; wage-adjusted supplies to labourers stay outside taxable sales.

Supply of food-grains and groceries by a planter to labourers as an estate amenity, with the value adjusted against wages and no profit motive, was treated as outside the concept of business under the Madras General Sales Tax Act, 1959. The inclusive definition of "business" removed only the need for actual profit accrual, but did not eliminate the requirement of a profit-making motive. On that construction, such supply transactions were not commercial sales exigible to tax, and the earlier legal position remained unchanged.

---

---

Issues: Whether the supply of food-grains and grocery to employees by a planter, without any profit motive and by adjusting the value against wages, constituted business and sale exigible to tax under the Madras General Sales Tax Act, 1959.

Analysis: The supply of commodities to the labourers was made as an amenity in outlying estates and not with a commercial object of making profit. Earlier decisions had held that such transactions were not in the course of business because the concept of business in the Act was used in a commercial sense. The later definition of "business" in the Madras General Sales Tax Act, 1959 was inclusive and removed only the requirement of actual accrual of profit, but did not dispense with the requirement that the activity be carried on with a profit-making motive. On that construction, the statutory definition did not alter the earlier legal position.

Conclusion: The transactions did not constitute business or taxable sales, and the petition was entitled to succeed.

---