Held, allowing the petition, that goods for the purpose of sales tax may be tangible or intangible property. They would become goods provided they have the attributes thereof regarding (a) utility (b) capability of being bought and sold and (c) capability of being transmitted, transferred, delivered, stored and possessed. If a software whether customised or non-customised satisfies these attributes it would be goods.
Therefore, the orders of the respondents holding the petitioner not entitled to use C forms for its purchases meant for use in the preparation of uncanned sotware were liable to be set asside.
