Consumables in dental treatment treated as part of medical service, not a separate deemed sale for tax

Consumables supplied and used during dental treatment, including implants and similar items, were treated as part of the composite medical service rather than as separate item-wise sales to patients. Because the articles were consumed in the course of treatment and formed part of the overall medical charge, the value of those consumables was not regarded as a taxable deemed sale. On that basis, the assessments were quashed.

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Issues: Whether the value of consumables supplied and used in the course of treatment in the dental hospital could be treated as a deemed sale and brought to tax.

Analysis: The supply of consumables, including implants and similar items used in treatment, was treated as part of the medical service and not as a separate sale. The assessment was based on the premise that the articles were consumed in the course of treatment and formed part of the composite medical charge, without a distinct item-wise sale to the patient.

Conclusion: The value of consumables used in the course of treatment could not be treated as a taxable deemed sale, and the assessments were quashed.

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