Madhya Pradesh High Court
M/S Prakash vs Commercial Tax Officer on 14 May, 2025
Author: Vivek Rusia
Bench: Vivek Rusia
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W.P. No.372 of 2005 & three other
IN THE HIGH COURT OF MADHYA PRADESH
AT I N D O R E
BEFORE
HON'BLE SHRI JUSTICE VIVEK RUSIA
&
HON'BLE SHRI JUSTICE GAJENDRA SINGH
ON THE 28th OF APRIL, 2025
WRIT PETITION No. 372 of 2005
M/S PRAKASH ALSPHALTINGS
Versus
COMMERCIAL TAX OFFICER AND OTHERS
WITH
WRIT PETITION No. 373 of 2005
M/S PRAKASH ALSPHALTINGS
Versus
COMMISSIONER TAX OFFICER AND OTHERS
WRIT PETITION No. 2179 of 2005
M/S PRAKASH
Versus
COMMERCIAL TAX OFFICER AND OTHERS
AND
WRIT PETITION No. 2180 of 2005
M/S PRAKASH
Versus
COMMERCIAL TAX OFFICER AND OTHERS
Appearance:
Shri Manoj Munshi, learned Senior Counsel assisted by Ms. Mahak Guru on
behalf of Shri Lucky Jain, learned counsel for the petitioner.
Shri Amit Agrawal, learned Senior Counsel assisted by Shri Arjun Agrawal,
learned counsel for the respondent / MPSITC.
Signature Not Verified
Signed by: RAVI PRAKASH
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W.P. No.372 of 2005 & three other
Shri Bhuwan Gautam, learned Government Advocate for the respondents /
State.
Heard on : 01st May, 2025
Delivered on : 14th May, 2025
ORDER
Per : Justice Vivek Rusia
Since the controversies involved in the above cases are
between the same parties, with the joint request of the parties, they
are analogously heard and decided by this common order.
By way of these petitions filed under Article 226 of the
Constitution of India, the petitioner has called into question the
legality of assessment and revisional orders passed under the Madhya
Pradesh Commercial Tax Act, 1994 treating its Build – Operate –
Transfer (in short ‘the BOT’ scheme as works contracts and holding
them liable to pay the commercial as well as entry tax. The challenge
is on the ground that there was no actual sale or no transfer of
property or goods during the relevant assessment years, and that there
was no taxable turnover or business activity until the commencement
of toll collection, which only started from 07.06.2001. These writ
petitions relate to the assessment years 2000-2001.
FACTS OF THE CASE
02. The petitioner is a company engaged in the business of
infrastructure development and in particular related to the
construction and maintenance of roads and highways under the BOT
scheme.
2.1. In the year 2000, the petitioner was awarded two separate
infrastructure contracts by the State Authorities. The first project was
granted by the Public Works Department (PWD), Katni Division,
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W.P. No.372 of 2005 & three other
under Agreement No. 6/DL/2000-2001 vide Work Order dated
08.05.2000 for the construction of the Katni Bypass (Pureni-
Khirehni) road having a length of 7.6 km. The second project was
awarded by the Madhya Pradesh State Industrial Development
Corporation (MPSIDC) vide letter dated 13.11.2000 for the
development and maintenance of a 27 km road between Mhow and
Ghatabillod.
2.2. Both contracts were under the BOT scheme, wherein the
petitioner was to construct, operate and maintain the above two roads
using its financial resources, with an authority to collect toll for a
fixed concession period i.e. 3941 days for the Katni project and 3351
days for the Mhow-Ghatabillod project to recover its investment and
expenditures. As per the terms of the concessional agreements, the
completed road with the facility was to be transferred back to the
respective authority at the end of the concession period without any
payment or any further claim.
2.3. According to the petitioner, construction work on both
projects was commenced during the financial year of 2000- 2001, but
as on 31.03.2001, the construction work was ongoing and had not
been completed. The completion certificate was issued later on, i.e.
on 07.06.2001, only after which toll collection began, hence, no
revenue from toll was earned during the Assessment Year 2000 –
2001. Despite this, the Commercial Tax Department initiated
proceedings under the Madhya Pradesh Vanijyik Kar Adhiniyam,
1994, and the Madhya Pradesh Sthaniya Kshetra Me Mal Ke Pravesh
Par Kar Adhiniyam, 1976, treating the BOT contracts executed by the
petitioner as taxable “works contracts”. The assessing officer held
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W.P. No.372 of 2005 & three other
that during the execution of the road projects, there was a transfer of
property in goods involved in the execution of the contract, which
constituted a deemed sale and held that the petitioner is liable for
commercial tax and entry tax.
2.4. In W.P. No. 373 of 2005 and W.P. No. 2180 of 2005, the
assessment under challenge is related to commercial tax; the
petitioner was subjected to assessment under the provisions of the
Madhya Pradesh Vanijyik Kar Adhiniyam, 1994, for the assessment
years 2000-01 and 2001-02. For the year 2000-01, the commercial
tax officer, Indore, vide order dated 12.02.2004, treated the purchase
and use of construction materials for its ongoing BOT projects as
involving deemed sales. In the absence of any recorded sale or
transfer of property in goods, the assessing authority estimated a
turnover of Rs. 4,79,57,042/- applying profit margins of 10% on
intra-State and 20% on inter-State purchases. On this basis,
commercial tax of Rs. 8, 16,637/- was imposed along with a penalty
of an equivalent amount. The revision of the petitioner against the
said assessment order was rejected by the Additional Commissioner
of Commercial Tax, Indore, vide order dated 12.10.2004. For the
subsequent year 2001-02, a similar assessment order dated
21.12.2004 was passed on the same reasoning and methodology,
which was likewise upheld in revision by order dated 07.04.2005.
2.5. In W.P. No. 372/2005 and W.P. No. 2179/2005, the
assessment under challenge is related to entry tax; the petitioner was
assessed under the Madhya Pradesh Sthaniya Kshetra Me Mal Ke
Pravesh Par Kar Adhiniyam, 1976, for both assessment years. For the
year 2000-01, the assessing authority by order dated 12.02.2004
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W.P. No.372 of 2005 & three other
determined that the petitioner had brought goods worth Rs.
4,36,40,514/- into the local area for use in its construction projects
and after allowing permissible deductions, the taxable quantum was
computed at Rs. 3,18,96,884/- on which Entry Tax of Rs. 3,30,502/-
was levied. Against this liability, the petitioner had already deposited
Rs. 2,74,300/-, resulting in a balance demand of Rs. 1,10,892/-. This
assessment was confirmed in revision by the Additional
Commissioner vide order dated 12.10.2004. For the subsequent year
2001-02, the Entry Tax assessment followed the same reasoning,
which was also confirmed and upheld in revision by order dated
07.04.2005. Hence, present writ petitions are before this Court for the
refund of tax with interest as per law.
SUBMISSIONS OF PETITIONER’S COUNSEL
03. Learned Senior Counsel for the petitioner submitted that the
assessments in question are liable to be set aside both in respect of
the levy of Commercial Tax and Entry Tax, as the same are based on
erroneous assumptions of law and fact. Learned Senior Counsel
submitted that the petitioner undertook construction of road projects
under the Build-Operate-Transfer (BOT) model for which the entire
cost of construction and maintenance was borne by the petitioner,
with the only consideration being the right to collect toll from users
of the completed road. Learned Senior Counsel submitted that since
there was neither contract for sale or supply of goods to the State nor
any transfer of property in goods for consideration which are
essential requirement to attract provisions of tax under the Madhya
Pradesh Commercial Tax Act, 1994 or Entry Tax Act, 1976 and
since the toll collected constituted only user fees paid by third parties
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and not consideration paid by the State Government thus the concept
of works contract or sale is not attracted.
3.1. Learned Senior Counsel further argued that the registration of
the petitioner under the Madhya Pradesh Commercial Tax Act, 1994
was necessitated solely by the statutory requirement under Section 5(5)
(a) read with Sections 22 and 23 which was required due to its purchase
of construction materials exceeding the statutory threshold limit.
However, such registration cannot be interpreted as constituting an
admission or acknowledgement of any taxable sale transaction. Learned
Senior Counsel argued that essential elements of “sale” as defined under
Section 2(t) of the Act, particularly the transfer of property in goods for
consideration, are entirely absent in the present case. Learned Senior
Counsel submitted that neither was there any transfer of goods nor any
receipt of consideration as contemplated under Section 2(u) of the Act
and also there was no turnover or taxable turnover as defined under
Sections 2(z) and 2(w) of the Act making the assessments
fundamentally erroneous and unsustainable.
3.2. Shri Munshi, learned Senior Counsel, submitted that the
assessing authorities have arbitrarily computed taxable turnover by
presuming a sale value based on the purchases of materials by the
petitioner and by applying speculative margins for profit and expenses.
Learned Senior Counsel submitted that the method adopted by the
Assessing Officer runs contrary to statutory requirements, which
mandate actual or tangible evidence of transfer or sale transactions.
3.3. Learned Senior Counsel submitted that Clause 19 of the
Special Conditions of the Concession Agreements explicitly stipulates
that any liability arising out of Sales Tax, Stamp Duty or similar levies
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due to transfer of property if any shall be borne exclusively by the
respondent authority concerned and therefore even on assuming without
admitting any liability towards such taxes the same stands indemnified
by the respondents themselves under the contractual provisions.
3.4. Learned Senior Counsel on the aspect of entry tax placed
reliance upon Section 3 of the Madhya Pradesh Sthaniya Kshetra Me
Mal Ke Pravesh Par Kar Adhiniyam, 1976, submitting that entry tax
liability arises only when goods are brought into a local area in the
course of business. Learned Senior Counsel categorically submitted that
during the financial year 2000-01 and the relevant period of 2001-02,
no business had commenced, and as such, the toll collection activities
began only after issuance of the completion certificate on 07.06.2001.
Thus, the goods used for construction were brought into the local area at
the pre-business commencement stage and thereby fell entirely outside
the purview of entry tax.
3.5. Learned counsel submitted that the audited balance sheets of the
petitioner also reflect that all goods used in the course of project
construction were classified under “capital work in progress” and there
was no resale or market transaction of such goods. As such, no element
of commerce or business was involved in the inward movement of
goods to attract the provisions of the Entry Tax Act. Reliance is placed
on this court order in Samta Foods Limited v/s Assistant Commissioner
of Commercial Tax (Writ Petition No.436 of 2005).
3.6. Learned Senior Counsel finally argued that the petitioner is not
disputing that in the BOT project the the petitioner is not liable to pay
commercial and entry tax, but they are liable to pay after completion of
the concessional period. Learned Senior Counsel submitted that the
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petitioner may be subjected to these two taxes after completion of work
and the concessional period, but not in every financial year, as during
this period, there was no sale or purchase.
3.7. Learned Senior Counsel, thus, prayed for quashment of the
impugned commercial tax and entry tax assessments and revisional
orders. In support of the aforesaid contentions, reliance has been
placed upon several judgments delivered by this Court in the casesof
Perfect Pottery Corporation Limited v/s Commercial Sales tax
(MCC No.123 of 1986, NTPC Limited v/s State of Madhya
Pradesh (Writ Petition No.2024 of 2008), Maihar Cemet v/s
Assistant Commissioner of Sales Tax reported in 1985 (60) STC
210; Makson Nutrition Food Private Limited v/s Assistant
Commissioner (Writ Petition No.8475 of 2015) and Surya Roshani
Limited v/s The State of Madhya Pradesh (Writ Petition No. 743 of
2011.
SUBMISSIONS OF STATE’S COUNSEL
04. Learned Government Advocate for the respondent / State
submitted that the impugned assessment and revision orders have been
passed in accordance with law and are fully justified both on facts and
legal principles. It has been submitted that the activities undertaken by
the petitioner under the Build-Operate-Transfer (BOT) model squarely
fall within the definition of “works contract” of the Madhya Pradesh
Vanijyik Kar Adhiniyam, 1994 and also attract the deemed sale
provision under Article 366(29A)(b) of the Constitution of India.
Learned Government Advocate submitted that the petitioner had
executed infrastructure works involving supply and incorporation of
goods in the course of construction of roads, which amounts to transfer
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W.P. No.372 of 2005 & three other
of property in goods for valuable consideration and is accordingly liable
to Commercial Tax.
4.1. Learned Government Advocate further submitted that the BOT
model does not alter the taxable character of the transaction, and the fact
that the State has not made a direct monetary payment is immaterial, as
the right to collect toll from users for a specified concession period
constitutes deferred consideration. Learned counsel submitted that the
petitioner was under a contractual obligation to deliver completed
infrastructure works, and the completed facility ultimately vests with the
State after the concession period, and thus, there is a clear transfer of
property in goods involved in the execution of a works contract.
Learned Government Advocate submitted that the assessment was made
by applying standard methods of computation based on the cost of
goods purchased and utilised by the petitioner in the course of execution
of the project, with a reasonable addition made towards profit and
incidental charges as per departmental norms and following all statutory
norms.
4.2. Learned Government Advocate argued with respect to Entry Tax
that since the petitioner being a registered dealer had brought goods
such as cement, steel, bitumen and other construction materials into the
local area in large quantities and that the entry of such goods was clearly
in the course of business as contemplated under Section 3 of the
Madhya Pradesh Entry Tax Act, 1976 thus he was liable to pay entry
tax.
4.3. Learned Government Advocate submitted that the petitioner had
embarked on a commercial venture by entering into concession
agreements for infrastructure development with the objective of earning
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toll revenue, and therefore, the activity amounts to business within the
extended definition under the Entry Tax Act. Learned Government
Advocate submitted that the point of commencement of toll collection is
not the determining factor of the commencement of business, and so
long as the entry of goods is linked to an ongoing commercial purpose
the tax is lawfully attracted.
4.4. Learned Government Advocate submitted that the petitioner has
not disputed the fact of purchase and entry of goods during the relevant
assessment years and the classification of the project as capital work-in-
progress or the absence of declared turnover cannot defeat the statutory
charge under the taxing enactments. Learned counsel submitted that the
assessments have been made after examining the returns, books of
account and materials on record and do not suffer from any procedural
or legal infirmity.
4.5. Finally, the learned Government Advocate submitted that the
impugned assessments and penalty orders are valid and sustainable in
law and prayed that the writ petitions be dismissed.
APPRECIATION & CONCLUSION
05. Learned Tax Consultant, who appeared on behalf of the
petitioner before the Assessing Authority argued only one ground that
in case of works contract, the ownership of the land on which the
road is to be constructed, remains with the Government, but in BOT,
the ownership is temporarily transferred to the contractor for
construction of road and said land would be reverted to the
Government after completion of construction and concessional period
without payment of any consideration. In case, the contractor being
an owner invests any amount or material that would not come within
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the purview of commercial tax or entry tax.
06. The aforesaid submission was rightly rejected by the
Assessing Authority. There is no such transfer of ownership or
deemed ownership in favour of the contractor during the construction
of the road and during the concessional period under the BOT
scheme. The Government always remains the owner of the land both
in works contracts or in BOT, and only possession is given to the
contractor to construct the road and recover the cost of construction
from the public or passengers by way of toll. As held by the Division
Bench of this Court in the case of Ashoka Infraways Private
Limited v/s The State of Madhya Pradesh & Others (Writ Petitions
No.2883 of 2008), apart from the Government, no one has the
authority to collect the toll or service charges from any person. If that
authority has been given to the contractor in the BOT scheme, instead
of making direct payment for the construction of the road, there
would be no escape from the tax liability on the contractor.
07. During the arguments, Shri Munshi, learned Senior Counsel
submitted that after the judgment passed by this Court in case of
Ashoka Infraways (supra), the petitioner is not disputing that no
commercial or entry tax is liable to be paid by the respondent in BOT,
but such tax is liable to be paid only after completion of the work and
not during the construction period when there is no sale or purchase
of materials with the Government. Admittedly, these arguments were
not raised before the Assessing Authority as well as Appellate
Authority.
08. Shri Manoj Munshi, learned Senior Counsel has also argued
that the work contract was issued to the petitioner on 08.05.2000 and
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W.P. No.372 of 2005 & three other
on 07.06.2001, the completion certificate was issued. In the balance
sheet, the petitioner showed that the work was not completed as a
capital work was in progress, hence, there is no liability of tax
contract under the BOT project. It is further submitted that during the
Assessment Year – 2000 – 01, the business was not commenced by
the petitioner with respect to these two projects and also there was no
transfer of property or goods as evident from the balance-sheet as
there is no sale as provided under Section 2(u) and there is no
turnover under Section 2(z) and taxable turn over under Section 2(w)
of the Act of 1994. The Assessing Authority has not considered this
fact and passed the order of assessment.
09. According to the petitioner, the tax has been assessed vide
order dated 12.02.2004 on amount of sale of Rs.4,59,57,042/- on the
basis of purchase of materials or goods used for the purpose of
construction of road by adding 10% in the total local purchase and
20% in the inter-state purchase towards profit and other expenses.
Since there was no sale in the books of account of the petitioner as
the petitioner did not receive any consideration for such alleged sale,
the tax on the basis of assumption has wrongly been imposed.
10. Section 2(r) of the M.P. Commercial Tax Act, 1994 (in short
‘the Act of 1994’) defines the ‘raw material’ which means an article
used as an ingredient in any manufactured goods, or an article
consumed in the process of manufacture and includes fuels and
lubricants required for the process of manufacture. For the purpose of
construction of a road, the raw material would be cement, concrete,
tar, sand, crushed stone, etc., which shall also include diesel used as
fuel in D.G. sets for the generation of electricity for running the plant
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and machinery.
11. Section 2(t) of the Act of 1994 defines ‘sale’ means a transfer
of property in goods for cash or deferred payment or for other
valuable consideration. In a works contract, the contractor, while
constructing a road submits a running bill to the Government and the
Government pays the bill from time to time, but under BOT scheme,
the contractor does not submit bills to the Government instead invests
its own money in the purchase of raw materials to construct the road.
In lieu of payment of running bills, the Government gives authority
to the contractor to recover the cost of construction by collecting a
toll during the concessional period. Therefore, instead of payment in
cash, there is a provision in the BOT for deferred payment or other
valuable consideration. As per this definition, there is a payment of
the contractor by way of toll on a deferred period i.e. concessional
period. Section 2(t)(ii) says that a transfer or property in goods,
whether as goods or in some other form, is involved in the execution
of a works contract. Construction of a road, no doubt, is a works
contract, but instead of adopting the procedure applicable in a normal
works contract, new methodology has been adopted i.e. build, operate
and transfer. By way of agreement between the Government and the
contractor, it is agreed that the Government shall provide a place or
land for the construction of the road, the contractor will invest its
money for the construction of the road and thereafter, recover by way
of toll. The Government, instead of making payment directly for the
construction of the road, gives the right to the contractor to recover
the costs by way of toll during the concessional period.
12. As discussed above, as per the BOT scheme, the payment to
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the petitioner for the work done was deferred by way of toll after
completion of the concessional period, which doesn’t mean that there
was no sale during the Assessment Year 2000 – 01. As per the scheme
of the commercial tax and entry tax, the tax is liable to be paid every
year. Only the mode of payment was deferred, which has not been
explained in the definition of ‘sale’ in Section 2(t)(i) & 2(t)(ii) of the
Act of 1994. Section 2(t)(vi) also clarifies that sale, with its
grammatical variations and cognate expressions, means that a transfer
of right to use any goods for any purpose (for a certain period) for
cash, deferred payment, or other valuable consideration will also be
treated as a sale.
13. In the case of Bharat Aluminium v/s The Commissioner of
Sales Tax reported in 1996 (29) VKN 91 MP, this Court held that for
exchange of one item for another item is a sale. As per Rule 33 of the
M.P. Commercial Tax Rules, 1995 (in short ‘the Rules of 1995’) also,
the dealer shall specify in the return its turnover, the details of the
sale/purchase for other than money consideration. The Assessing
Officer shall fix the value of consideration in money for the purpose
of determining the taxable turnover. For ready reference, Rule 33 is
reproduced below:-
”33.Returns relating to consideration other than money
consideration
Every dealer who has bought or sold goods for valuable
consideration other than money shall separately specify in the
return of turnover, which he is required to submit under these
rules, the quantity of goods so bought or sold and the
description in sufficient detail of the valuable consideration for
which the goods were bought or sold. The assessing authority
shall fix the value of such consideration in money for the
purpose of determining the turnover and assessment of the tax
payable under the Act.”
14. In the present case, the petitioner, being a dealer, purchased
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materials for construction of the road and he was liable to specify in
the return of turnover, which is required to be submitted under this
rule i.e. quantity of goods so bought or sold and its description like
details of valuable consideration. The Assessing Authority, thereafter,
shall fix the value of consideration in money for the purpose of
determining the turnover and assessment of the tax payable under the
Act. Therefore, even at the time of relevant assessment year, the
money was not paid to the petitioner by the Government, but value of
such consideration in money for the purpose of determining the
turnover can be fixed by the Assessing Authority because it is a case
of deferred payment by State by giving right to recover by way of
toll.
15. As per Rule 37 of the Rules of 1995, every dealer by whom
the tax is payable under the Act shall pay the tax quarterly and shall
furnish an annual return under Rule 19. As observed by the revisional
authority in the order, the petitioner has not raised any objection in
respect of the assessment of tax by the Assessing Authority.
Therefore, even under the works contract under the BOT scheme, the
annual return can be submitted by the contractor, and the contractor
does not need to wait till the conclusion of the concessional period to
pay the commercial and entry taxes.
16. Admittedly, the petitioner is a dealer then certainly liable to
pay taxes by filing a return on the goods purchased and brought into
the State in execution of the works contract. The words ‘project’ and
‘project cost’ are defined in Clauses W3 and W4 of the agreement.
According to the project, it shall mean survey, investigation, studies,
design, construction, reconstruction, improvement, strengthening and
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repair. All the work related to the maintenance of the road, renewal of
surface, bridge, tunnel, culvert, etc. and the cost offered to invest by
the entrepreneur for completion of the aforesaid project shall be a
project cost. As per clause 4.1, the land for the construction of the
bypass road will be handed over on a license basis to the contractor
for the concessional period, and this will not amount to the transfer of
ownership or lease of the land. Clause 6 made it clear that the
entrepreneur will have to make their own arrangements for procuring
the material required for work.
17. The Government’s right was absolutely reserved to take over
the facility at any time after completion of the work, even during the
concessional period, and in such circumstances, the entrepreneur
shall be eligible for compensation for the unrecovered amount along
with the interest. No permanent structure, except the toll collection
booth, site office, etc. shall be permitted to be constructed by the
entrepreneur. As discussed above, the period of collection of the toll
upon construction of the Dewas By-pass road was fixed for a fixed
concession period, i.e. 3941 days for the Katni project and 3351 days
for the Mhow – Ghatabillod project, by taking into consideration all
the costs and expenses incurred in the construction work. The
petitioner was required to make all arrangements for the money for
construction of the bypass road, the petitioner was given the right to
collect the toll after completion of the construction of the road for
which period as above was fixed after considering the total cost of
construction of the project and its recovery by way of collection of
tolls. After the expiry of the said period, the petitioner shall not have
any claim on the road as well as on a toll.
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18. It is a settled law that no person has a right to collect a toll or
any tax from private persons for using the road. The State
Government gave the right to collect the tolls to the petitioner from
the vehicles passing through the road for a definite period to recover
only the cost of construction, i.e. the sale amount or the contract
value. The contract amount is liable to be paid to the contractor as a
deferred payment by authorising him to recover the toll tax, and
except for this, there is no difference in the work done under the BOT
scheme and in the normal works contract. This issue has been
considered in detail by the Full Bench of this Court in the matter of
Viva Highways v/s Madhya Pradesh Road Development Authority
reported in 2017 (2) M.P.L.J. 681 in which it has been held that the
works contract means an agreement must be in writing, it must be
executed of any work related to the construction, repair or
maintenance of any building, superstructure or other amenities
mentioned in the definition. Any agreement, by whatever name it is
called, if it falls within the meaning of a definition of works contract
as per the definition of 1983, must be treated as a works contract.
19. Therefore, in view of the above, the petitioner is
misconstruing the terms of the agreement and the construction of
Dewas bypass road on BOT basis that it does not amount to
execution of works contract, the petitioner executed the works
contract on the land belonging to the State Government and
recovered the construction and maintenance cost by way of toll with
due permission from the State Government, it is nothing but a
deferred payment by a mode of recovery of toll. The land on which
roads were constructed by the petitioner remained in the ownership
Signature Not Verified
Signed by: RAVI PRAKASH
Signing time: 14-05-2025
19:15:50
NEUTRAL CITATION NO. 2025:MPHC-IND:12661
18
W.P. No.372 of 2005 & three other
of the State. Hence, we do not find any substance in these writ
petitions.
20. Accordingly, Writ Petition No.372 of 2002 as well as Writ
Petition Nos.373 of 2005, 2179 of 2005 & 2180 of 2005, being
devoid of merit and substance, are hereby dismissed.
21. Let singed copy of this order be kept in W.P. No.372 of 2005
and photocopy of the same be kept in the connected writ petitions.
(VIVEK RUSIA) (GAJENDRA SINGH)
JUDGE JUDGE
Ravi
Signature Not Verified
Signed by: RAVI PRAKASH
Signing time: 14-05-2025
19:15:50
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