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Issues: Whether the movement of goods from Faridabad to Delhi pursuant to contracts for manufactured-to-specification goods constituted inter-State sales under section 3(a) of the Central Sales Tax Act, 1956, and whether the sales tax authorities at Faridabad had the right to levy and collect tax on such sales.
Analysis: The goods were future goods manufactured only after pre-existing contracts of sale had been entered into and were produced according to the buyers' specifications. The movement from Faridabad to Delhi was not a mere matter of convenience or an independent stock transfer; it was the only practical mode of performing the contracts. On that basis, the movement was a necessary incident of the contracts and the sales were occasioned by them within section 3(a). For goods of this kind, appropriation under section 4(2)(b) occurred when the goods were manufactured and set apart in accordance with the contracts, and the absence of passage of property to the buyers did not alter the inter-State character of the sales. As the sales were inter-State sales, the appropriate State authorities at Faridabad were competent to assess the tax.
Conclusion: The sales were inter-State sales under section 3(a) of the Central Sales Tax Act, 1956, and the tax was payable to the authorities at Faridabad, not Delhi.