Inter-State sale test: later buyer-driven movement after local delivery does not make the transaction inter-State.

Movement of goods from one State to another constitutes an inter-State sale under Section 3(a) of the Central Sales Tax Act only when that movement is occasioned by, or is an incident of, the contract of sale and forms one integrated transaction. Where a branch office purchases goods in the seller's State, the sale is completed there on payment and delivery, and the buyer later dispatches the goods to another State on its own account, the required legal nexus is absent. On these facts, the transaction was not an inter-State sale and remained taxable as a local sale under the Andhra Pradesh General Sales Tax Act, 1957.

---

---

Issues: Whether the purchase and subsequent movement of beedi leaves from Andhra Pradesh to Maharashtra constituted an inter-State sale under Section 3(a) of the Central Sales Tax Act, 1956, or a local sale exigible to tax under the Andhra Pradesh General Sales Tax Act, 1957.

Analysis: A sale falls within Section 3(a) only when the movement of goods from one State to another is occasioned by, or is an incident of, the contract of sale. The controlling test is whether the sale and movement form one integrated transaction with a real nexus between them. Here, the branch office in Andhra Pradesh participated in the auction, purchased the goods from the State department, and the sale was completed on payment and delivery at the seller's godown in Andhra Pradesh. The later dispatch of the goods to the head office in Maharashtra was undertaken by the purchaser after the concluded sale and was not part of the sale transaction with the seller. The movement therefore lacked the necessary legal connection with the sale.

Conclusion: The transaction was not an inter-State sale and was exigible to tax under the Andhra Pradesh General Sales Tax Act, 1957.

---