SIM cards used as part of telecom service are not exigible to octroi when not sold separately.

SIM cards used as an integral part of telecom services do not constitute goods liable to octroi when they are not sold as distinct objects of sale. The controlling test is whether the SIM card is independently sold as goods or merely forms part of the service rendered; where the transaction is predominantly for service and the SIM card has no separate commercial identity, octroi cannot be levied on it. The stated ratio is that only goods entering municipal limits for consumption, use, or sale are exigible to octroi, and a SIM card embedded in the service supply falls outside that levy.

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Issues: Whether SIM cards distributed and sold within municipal limits are liable to octroi as goods.

Analysis: Octroi is a levy on entry of goods into municipal limits for consumption, use, or sale. The controlling question was whether SIM cards could be treated as goods independently of the telecom service. The reasoning followed the settled position that where a SIM card is not sold as a separate object of sale but forms part of the service rendered, it does not acquire the character of goods for octroi purposes. The transaction was viewed as predominantly one for service, with no independent sale of SIM cards as goods.

Conclusion: SIM cards are not liable to octroi as goods when they are not sold independently of the services provided.

Ratio Decidendi: A SIM card used as an integral part of a telecom service, and not sold as a distinct object of sale, does not constitute goods exigible to octroi.

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