Software as goods under sales tax law requires larger Bench consideration after competing views on intangibility and tangible media.

Computer software, including standardised and custom-made software, is discussed as a possible form of "goods" under the Andhra Pradesh General Sales Tax Act, with the analysis noting the competing distinction between intangible intellectual property and tangible media such as discs and tapes. Earlier authorities on software and related information products are noted, and the issue is treated as having wide implications requiring further authoritative consideration. No final ruling on taxability was rendered, and the matter was directed for placement before the Chief Justice of India for reference to a larger Bench.

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Issues: Whether software, including standardised and custom-made software, constitutes "goods" for the purposes of the Andhra Pradesh General Sales Tax Act, 1957, and whether the question required further authoritative consideration.

Analysis: The judgment records competing submissions on the nature of computer software, including the distinction between intangible intellectual property and tangible media such as discs and tapes, and notes earlier decisions touching the characterization of software and related information products as goods. It observes that the issue has wide implications and that further consideration is necessary.

Outcome: No final adjudication on taxability was rendered; the papers were directed to be placed before the Chief Justice of India for reference to a larger Bench.

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