High seas sale not proved; imported goods remained taxable under the State sales tax law.

Imported goods were claimed to have been sold by transfer of documents while in transit on the high seas, so as to fall within Article 286(1)(b) and escape tax under the Andhra Pradesh General Sales Tax Act, 1957. The authorities found no relevant or cogent evidence proving the exact point of sale or showing that the transactions occurred before the goods were landed, and the shipment dates and document transfers did not establish a sale outside Indian waters. Those factual findings were affirmed by the High Court. The high seas sale claim was therefore not proved, and the sales remained taxable under the State Act.

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Issues: Whether the sales of imported goods were effected on the high seas so as to fall within the protection of Article 286(1)(b) of the Constitution of India and remain outside the levy under the Andhra Pradesh General Sales Tax Act, 1957.

Analysis: The appellant asserted that the imported goods were sold by transfer of documents while in transit on the high seas. The authorities found that there was no relevant or cogent evidence to establish the exact point of sale or to show that the transactions took place before the goods were landed. The dates of arrival of the ships and transfer of documents did not prove that the alleged sales occurred while the goods were outside the waters of India. Those factual findings were affirmed by the High Court.

Conclusion: The claim of high seas sale was not proved, and the sales were held liable to tax under the Andhra Pradesh General Sales Tax Act, 1957.

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