Inter-State sale turns on contractual movement of goods across State borders, making the turnover taxable in the destination State.

Inter-State sale arises under the Central Sales Tax Act when the contract of sale itself occasions movement of goods from one State to another. Here, the disputed turnover was treated in the assessee's books as sales, orders were placed through its Madras office, and goods moved from Chennai to Nellore and Chittoor pursuant to those contracts. The material did not establish independent local sales in Andhra Pradesh, and the prior Andhra Pradesh proceedings were not treated as covering the same turnover and assessment year. On those facts, the turnover was correctly characterised as inter-State sales taxable in Tamil Nadu.

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Issues: Whether the disputed turnover represented inter-State sales exigible to tax in Tamil Nadu under section 3(a) of the Central Sales Tax Act, 1956.

Analysis: Inter-State sale under section 3(a) arises only where the sale or purchase occasions movement of goods from one State to another, and the movement must be the result of the contract of sale. On the facts, the assessee's own books treated the disputed turnover as its sales, the orders were placed through the Madras office, the goods were moved from Chennai to Nellore and Chittoor pursuant to those contracts, and the material did not establish that the turnover represented independent local sales in Andhra Pradesh. The prior Andhra Pradesh proceedings were not treated as for the present turnover and assessment year. The facts were held to be in substance similar to the earlier Madras decision relied upon by the Revenue.

Conclusion: The turnover was rightly held to be inter-State sales taxable in Tamil Nadu, and the assessee's challenge failed.

Ratio Decidendi: Where a sale contract through the assessee's office causes the movement of goods from one State to another, the transaction is an inter-State sale taxable under section 3(a) of the Central Sales Tax Act, 1956, notwithstanding assertions of local sales in another State.

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