Inter-State sales arise when goods move under prior buyer contracts, even if routed through a depot or shown as self.

Goods moved from Tamil Nadu to Bombay under prior contracts with identified out-of-State purchasers were treated as inter-State sales because the movement was occasioned by the buyers' orders and the contractual nexus was clear. Routing the consignments through a depot keeper, describing them as self-addressed, or using banking arrangements did not change the character of the transactions when delivery was intended for specific purchasers. The Bombay transactions were therefore taxable as inter-State sales under the Central Sales Tax Act, and the contention that they were only depot sales was rejected.

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Issues: Whether the sales effected through the Bombay depot were inter-State sales liable to tax under the Central Sales Tax Act.

Analysis: The decisive question was whether the movement of goods from Tamil Nadu to Bombay was referable to prior firm orders placed by identified out-of-State purchasers. The fact that orders were routed through a depot keeper, that the consignments were shown as addressed to self, and that payment was secured through banking arrangements did not alter the character of the transactions where the goods moved in pursuance of concluded contracts and were intended to be delivered to the specific buyers. The presence of an intermediary or depot arrangement was held to be immaterial when the movement of goods was inextricably linked with the buyers' contracts.

Conclusion: The Bombay transactions were inter-State sales and taxable under section 3(a) of the Central Sales Tax Act. The contention that they were merely depot sales was rejected.

Final Conclusion: The appeal failed, and the Board's treatment of the disputed transactions as inter-State sales was upheld.

Ratio Decidendi: Where goods move from one State to another in pursuance of a prior contract with an identified purchaser, the sale is an inter-State sale notwithstanding routing through a depot, intermediary, or a consignment shown as self, if the movement is occasioned by the contract and the nexus is clear.

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