Meal vouchers under a regulated payment system are not goods, so octroi and local body tax do not apply.

Meal vouchers issued under a regulated payment system were not "goods" for octroi or local body tax purposes because the issuer did not sell a commodity, but only facilitated settlement under the Payment and Settlement Systems Act, 2007 and RBI directions. The vouchers were non-transferable, not independently marketable, and functioned only as a payment medium within an employer perquisite arrangement; the underlying food or goods were supplied by affiliate merchants, not by the issuer. On that basis, the transaction retained the character of a service rather than a sale of goods, and the vouchers were held not to fall within Section 2(25) of the Maharashtra Municipal Corporation Act, 1949, so no octroi or local body tax was payable.

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Issues: Whether meal vouchers issued under a regulated payment system constitute "goods" for the purpose of octroi or local body tax.

Analysis: The vouchers were not sold as a commodity by the issuer but were part of a regulated payment mechanism under the Payment and Settlement Systems Act, 2007 and RBI directions. The issuer merely facilitated settlement between customers, employees, and affiliate merchants, retained service charges, and did not itself supply the underlying food or goods. The vouchers were non-transferable, not independently traded in the market, and functioned only as a means of enabling the employer's perquisite arrangement for employees. On that footing, the essential character of the transaction was provision of service, not sale of goods.

Conclusion: The meal vouchers were not "goods" within Section 2(25) of the Maharashtra Municipal Corporation Act, 1949 and were not liable to octroi or local body tax.

Ratio Decidendi: An instrument used only as a non-transferable facilitative medium in a regulated payment-service arrangement, and not independently sold or marketable as a commodity, is not "goods" for entry-tax purposes.

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