Inter-State sale classification failed where factual findings showed the sale originated in Andhra Pradesh, not Tamil Nadu.

The Tribunal found, on the Andhra Pradesh assessment material, that the sale originated in Andhra Pradesh and was not an inter-State sale from Tamil Nadu. That factual conclusion meant the turnover was not liable to tax in Tamil Nadu under the Central Sales Tax Act, 1956, and the challenge disclosed no legal infirmity warranting interference in revision. As the dispute turned entirely on that factual finding, no question of law arose for consideration, and the Tribunal's finding in favour of the assessee was left undisturbed.

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Issues: Whether the turnover in question was liable to tax in Tamil Nadu as an inter-State sale under the Central Sales Tax Act, 1956, when it had already been assessed to tax in Andhra Pradesh as an intra-State sale.

Analysis: The Tribunal relied on the assessment material from Andhra Pradesh and recorded a factual finding that the sale emanated from Andhra Pradesh and was not an inter-State sale from Tamil Nadu. That finding was based on material and did not disclose any legal infirmity warranting interference in revision. As the challenge depended on the Tribunal's factual conclusion, no question of law arose for consideration.

Conclusion: The revision was dismissed, and the Tribunal's finding in favour of the assessee was left undisturbed.

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