Finished goods treated as inter-State sale, not stock transfer, where nothing further remained to be manufactured.

Goods moved from one manufacturing unit to another were treated as finished tin containers, not semi-finished stock transferred for further processing. On the evidence, the articles were cylindrical bodies with top and bottom fitted, leaving nothing further to be manufactured by the assessee. The concurrent factual finding that the transfer was movement of complete goods supported treatment as an inter-State sale for Central sales tax purposes. The challenge that each transaction required separate examination did not disturb that finding, and the revision failed. The Tribunal's order sustaining Central sales tax was upheld in favour of the Revenue.

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Issues: Whether the goods transferred from the Sahibabad unit to the Murthal unit were semi-finished goods by way of stock transfer or finished goods liable to Central sales tax as inter-State sale.

Analysis: The revision challenged the Tribunal's finding that the articles moved from one unit to another were not mere semi-fabricated bodies but complete tin containers. The record referred to the goods as cylindrical bodies with the top and bottom fitted, leaving nothing further to be manufactured by the assessee. On that factual basis, the transfer was treated as movement of finished goods and not as a stock transfer of semi-finished goods. The challenge that each transaction should have been separately examined did not dislodge the concurrent factual finding recorded by the authorities below.

Conclusion: The transfer was rightly treated as an inter-State sale and not as a stock transfer of semi-finished goods; the finding was against the assessee and in favour of the Revenue.

Final Conclusion: The revision failed and the Tribunal's order imposing Central sales tax was sustained.

Ratio Decidendi: Where the goods moved between units are found on evidence to be finished products and not semi-finished materials, the transfer is liable to be treated as an inter-State sale for Central sales tax purposes.

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