SIM cards not treated as goods for entry tax, leaving no liability under the Entry Tax Act.

SIM cards were held not to be "goods" for entry tax purposes because, in the telecom context, they are integral to the service provided rather than independent items sold as goods. The Entry Tax Act's definition of "goods" had to be read consistently with the VAT enactment, and the earlier binding view on the same subject was treated as controlling. As a result, no liability under Section 3(1) of the Entry Tax Act, 1976 arose on SIM cards.

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Issues: Whether SIM cards are "goods" within the meaning of the Entry Tax Act, 1976 and hence liable to entry tax under Section 3(1).

Analysis: The reference turned on the character of SIM cards. The Court followed the earlier binding view that SIM cards, in the context of telecom services, are not sold as independent goods but are integral to the service provided. The definition clause in the Entry Tax Act required the meaning of "goods" to be understood consistently with the VAT enactment, and the earlier decision holding that SIM cards are not goods was treated as controlling. Since the prior decision on the same subject had already determined that SIM cards did not constitute goods for the relevant taxing purpose, entry tax could not be levied on them.

Conclusion: SIM cards are not goods for the purpose of entry tax, and no liability under Section 3(1) of the Entry Tax Act, 1976 arises.

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