Skip to content
Supreme Court GST Citator

Bharat Sanchar Nigam Ltd. v. Union of India

Composite transactions / dominant nature - provision-linked ratio, later-treatment and amendment-survival controls.

noindex,followReviewed 19 July 2026CA Nikhil Gupta and Kajri Singh
CourtSupreme Court of India
Year / citation2006 ยท (2006) 3 SCC 1
TopicComposite transactions / dominant nature
Linked lawCGST ss.2(30), 2(74), 8

Controlled proposition

Developed principles for separating goods and services under the pre-GST constitutional framework; use cautiously under GST, which expressly taxes composite and mixed supplies.

Use boundary: This is a controlled research proposition, not a substitute for the official judgment. The proposition must be matched to the exact facts, relief and statutory version.

Provision-linked decode

The decision is relevant to CGST ss.2(30), 2(74), 8. Start by identifying the transaction period, the provision then in force and the exact issue decided. Separate the ratio from observations, concessions and directions confined to the case.

For current GST use, prepare a redline between the decided text and the present Act, Rules, notifications and portal procedure. Where the case concerns a pre-GST regime, record which interpretive proposition survives and which has been displaced by sections 7, 8, 16, 17, 54, 83 or the allied GST statutes.

Later-treatment and amendment-survival controls

Verify official identity.

Capture case number, coram, date, neutral/reported citation and official PDF hash.

Pinpoint the ratio.

Record the exact paragraphs supporting each proposition and the relief actually granted.

Check later history.

Confirm whether subsequent GST-specific judgments, constitutional amendments or statutory amendments alter the proposition.

Apply current law.

Do not transpose a pre-GST ratio mechanically; identify which proposition survives into the GST text.

Practical example

A finance team proposes to cite this decision in a GST position paper. The reviewer first maps the case to CGST ss.2(30), 2(74), 8, confirms the tax period and current wording, attaches the official judgment, highlights the ratio paragraphs, records later treatment and explains factual similarities and differences. The conclusion is not approved where the team relies only on a headnote.

Official source and validation status

Supreme Court official locator: Open official source

Pinpoint gate: No proposition should be quoted in a live matter until the official PDF, exact paragraph, statutory version and later treatment are captured in the citator register.

Finin2min Q&A

Can the case summary replace the judgment?

No. The full official judgment, exact paragraph and later history control.

What is the amendment-survival test?

Compare the provision and Rule decided with the current text, effective date and retrospective amendments.

How should contrary High Court decisions be handled?

Apply the jurisdictional hierarchy, identify conflict, check Supreme Court treatment and disclose the competing view.