F.O.R. notation alone does not fix the situs of sale; the full contract controls sales tax treatment.

F.O.R. Khandwa terms do not by themselves establish that delivery occurred inside Madhya Pradesh for sales tax purposes; the situs of sale must be determined from the whole contract. Payment against railway receipts also could not, on its own, prove an intra-State sale. Because the Board of Revenue had relied only on the F.O.R. notation and had not examined all contractual terms, the transactions could not be assessed as inside sales on that basis alone. The matter was therefore remitted for reconsideration of the revision petitions in light of the complete contract.

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Issues: Whether turnover arising from sales on F.O.R. Khandwa terms and payment against railway receipts could be treated as sales taking place within Madhya Pradesh and thus be assessed to sales tax in the State.

Analysis: The assessment authorities and the Board of Revenue had treated the transactions as inside sales only because the contracts mentioned F.O.R. Khandwa as the place of delivery. The Court held that the expression F.O.R., depending on context, does not by itself establish that delivery took place inside the State; when used with price, it indicates an inclusive price and not necessarily local delivery. The Board had not examined the other contractual terms, including payment against railway receipts, and therefore had not found on the full contract whether the sales were intra-State sales.

Conclusion: It could not be held on the basis of F.O.R. Khandwa and payment against railway receipts alone that the turnover was assessable to sales tax as inside sales in Madhya Pradesh.

Final Conclusion: The references were answered in favour of the assessee, and the matter was sent back for reconsideration of the revision petitions on the basis of all contractual terms.

Ratio Decidendi: F.O.R. notation by itself does not conclusively determine the situs of sale for sales tax purposes, and the character of the transaction must be decided from the whole contract and its terms.

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