Inter-State sale under CST requires movement of goods to be part of the sale contract, not just invoice references.

A sale falls within Section 3(a) of the Central Sales Tax Act, 1956 only if the contract itself contemplates or necessarily involves movement of goods from one State to another, making that movement an integral part of the bargain. Mere reference to CST registration numbers or lorry numbers in invoices is not enough to prove an inter-State sale. The burden rests on the Revenue to show that the transport was occasioned by the contract of sale. On the facts discussed, it was equally plausible that the goods were sold and delivered within the State, with any later despatch or return occurring after completion of the sale or at the purchaser's direction.

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Issues: Whether the disputed sales of groundnut seeds were inter-State sales under Section 3(a) of the Central Sales Tax Act, 1956 or completed local sales, and whether the Revenue had proved that movement of goods from one State to another was occasioned by the contract of sale.

Analysis: A sale is an inter-State sale only when the contract itself contemplates or necessarily involves movement of goods from one State to another, or when such movement is an integral incident of the bargain. Mere mention of CST registration numbers or lorry numbers in the bills does not by itself establish that despatch was part of the sale contract. The onus lay on the Revenue to prove that the transportation was occasioned by the sale. The court found it equally plausible that the goods were sold and delivered within the State and that any later despatch or return of goods occurred after completion of the sale or pursuant to the purchaser's instructions.

Conclusion: The sales were not proved to be inter-State sales, and the Revenue failed to establish that the movement of goods was occasioned by the contract of sale.

Final Conclusion: The revision succeeded, and the tax treatment based on inter-State sale could not be sustained.

Ratio Decidendi: For a sale to fall within Section 3(a) of the Central Sales Tax Act, 1956, the movement of goods from one State to another must be occasioned by, and form an integral part of, the contract of sale; the burden to prove this lies on the Revenue.

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