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    <title>2009 (2) TMI 754 - ORISSA HIGH COURT</title>
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    <description>The decisive test was the true nature of the contract, assessed from its terms, the parties&#039; intention and the primary object of the transaction. A supply arrangement for photo-identity cards, made to specified specifications and involving data entry, photographing, storage and processing, was held to be predominantly skilled labour and service. The use of materials was merely incidental, and the cards had no commercial utility in the open market. The transaction was therefore a contract for work and labour, not a sale, and was not exigible to sales tax.</description>
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