Local delivery and acceptance fixed the sale in West Bengal, making the transaction liable to sales tax.

Goods delivered at Calcutta to the inspecting authority were held to be sold within West Bengal because the seller's contractual obligation ended on local delivery and approval. Payment became due immediately after inspection, and the later movement of goods to Kanpur was a subsequent governmental matter, not part of the seller's sale obligation. As no contractual inter-State movement formed part of the transaction, property passed on delivery and acceptance in West Bengal. The sale was therefore neither an outside-State nor an exempt inter-State sale, and sales tax was payable in West Bengal.

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Issues: Whether the sale of goods supplied under the contract was completed within West Bengal so as to attract sales tax, or whether it was exempt as an outside-State or inter-State sale.

Analysis: The contract contemplated delivery at Calcutta to the inspecting authority, who acted for acceptance of the goods, and payment was claimed in full immediately after such delivery and inspection. The obligation to forward the goods to Kanpur did not rest on the seller; it was only a subsequent matter for the Government, and the seller's duty ended on local delivery and certification. On the facts, there was no contractual movement of goods from one State to another as part of the sale transaction, and the subsequent despatch, if any, was not shown to be part of the seller's obligation. The property in the goods passed on delivery and approval in West Bengal, so the sale was neither outside the State nor exempt under Article 286.

Conclusion: The sale was completed within West Bengal and was liable to sales tax; the claimed exemption was not available.

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