Inter-State purchase character applies where goods move under an out-of-State sale arrangement, excluding local tax jurisdiction.

Purchases of gur and khand made by a dealer for and on behalf of an out-of-State principal were treated as inter-State purchases because the goods moved from one State to another in pursuance of the sale arrangement. The Tribunal's finding rested on evidence that the goods were dispatched on the same day or immediately thereafter, and the absence of disclosure of the principal's particulars to cultivators did not change the character of the transactions. As a result, the local taxing jurisdiction of U.P. did not apply, and the revision was rejected.

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Issues: Whether the purchases of gur and khand made by the dealer for and on behalf of an out-of-State principal were inter-State purchases so as to exclude the taxing jurisdiction of the State of U.P.

Analysis: The Tribunal's finding that the purchases were made for and on behalf of the out-of-State principal and that the goods were dispatched on the same day or immediately thereafter was based on appreciation of evidence. On those facts, the movement of goods from one State to another was in pursuance of the sale arrangement, and the absence of disclosure of the principal's particulars to the cultivators did not alter the character of the transactions.

Conclusion: The purchases were rightly treated as inter-State purchases, and the State of U.P. had no jurisdiction to levy tax.

Final Conclusion: The revision was without merit and was rejected, leaving the Tribunal's view on the taxability of the transactions undisturbed.

Ratio Decidendi: Where goods move from one State to another in pursuance of a sale arrangement for an out-of-State principal, the transaction is an inter-State purchase and is outside the taxing jurisdiction of the local State.

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