Independent scrutiny of each dispatch is required to distinguish stock transfers from inter-State sales; broad findings are insufficient.

In determining whether goods sent to branch offices are stock transfers or inter-State sales, the last fact-finding authority must examine each disputed dispatch independently on the relevant record. Broad or general findings are insufficient where the character of each transaction depends on its own facts, including whether movement of goods was occasioned by a contract of sale. The Tribunal's disposal of the second appeal by general observations, without independent scrutiny of the individual dispatches, was held unsustainable. The order was set aside and the matter was remitted for fresh adjudication in accordance with law.

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Issues: Whether the Tribunal, as the last fact-finding authority, was required to examine each disputed dispatch independently to determine whether the transactions were stock transfers or inter-State sales.

Analysis: The revision challenged the Tribunal's disposal of the second appeal by general observations without independent scrutiny of the individual dispatches to the different branches. In tax matters of this nature, the factual character of each transaction had to be determined separately on the relevant record, and a wholesale rejection based on broad findings was insufficient. The decision relied on the settled principle that the taxing authority must examine each transaction and ascertain whether the movement of goods was occasioned by a contract of sale or amounted to a stock transfer.

Conclusion: The Tribunal's order was unsustainable for want of independent consideration of the individual transactions, and the matter required fresh adjudication.

Final Conclusion: The revision succeeded, the Tribunal's order was set aside, and the appeal was restored to the Tribunal for decision afresh in accordance with law.

Ratio Decidendi: In determining whether goods moved to branch offices constitute stock transfers or inter-State sales, the last fact-finding authority must examine each transaction independently and cannot rest its decision on broad generalisations.

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