Direct causal connection under sales tax law governs purchase tax liability where goods are brought into the State.

The phrase "as a direct result of a sale" under section 18 was construed to qualify both the despatch or bringing of notified goods into Bombay and their actual delivery, so purchase tax liability arose only where that direct causal connection was established. On that reading, the assessee benefited from the interpretation, but the existing record did not show whether the vehicle had been brought into the State as a direct result of the sale. Because the necessary factual basis was incomplete, the liability question could not be finally determined and the matter required a supplementary finding on the remaining factual issue.

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Issues: Whether goods notified under section 18 of the Bombay Sales Tax (No. 2) Ordinance, 1952 became liable to purchase tax only when their despatch or bringing into the State and actual delivery were both the direct result of a sale to a buyer in the State of Bombay, and whether the matter required further factual inquiry on that point.

Analysis: The statutory expression "as a direct result of a sale" was held to govern not merely the words "actually delivered" but also the earlier words describing goods "despatched or brought" from outside the State. On that construction, liability to purchase tax arose only where the notified goods were brought into the State as a direct result of a sale and were actually delivered to the buyer. The existing record, however, did not show whether the vehicle in question had been brought into Bombay as a direct result of the sale to the assessee, and the factual basis necessary for final determination was therefore incomplete.

Conclusion: The interpretation of section 18 favoured the assessee, but the question of liability could not be finally answered without a supplementary finding on the factual issue of direct causal connection between the sale and the bringing of the vehicle into the State.

Final Conclusion: The matter was sent back for a supplementary statement of facts on the remaining factual issue, and the assessment dispute was not finally concluded on the merits.

Ratio Decidendi: Under section 18, the phrase "as a direct result of a sale" qualifies both the bringing or despatch of the notified goods into the State and their actual delivery, so purchase tax liability depends on that direct causal connection being established.

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