Section 6(2) exemption under the Central Sales Tax Act did not cover inter-State sales to Government institutions.

The unamended Section 6(2) of the Central Sales Tax Act, 1956 was confined to sales to registered dealers and did not extend to inter-State sales made to Government institutions, because the statute deliberately referred to Government separately in Section 8 and omitted it from Section 6(2). The simultaneous amendment of both provisions by Act No. 31 of 1958 reinforced that the legislature intended different treatment for exemption and concessional taxation. Accordingly, the claimed exemption was not available for sales to Government institutions.

---

---

Issues: Whether the unamended Section 6(2) of the Central Sales Tax Act, 1956 extended exemption to inter-State sales made to Government institutions, notwithstanding the absence of any reference to Government in that provision.

Analysis: The distinction drawn by the statute between sales to registered dealers under Section 6(2) and sales to Government or registered dealers under Section 8 indicated that the omission of Government from Section 6(2) was deliberate and not accidental. The simultaneous amendment of both provisions by Act No. 31 of 1958, without retrospective extension of the amended exemption, supported the view that the legislature intended different treatment for exemption and concessional taxation.

Conclusion: The unamended Section 6(2) did not apply to sales made to Government institutions, and the assessee was not entitled to the claimed exemption.

---