Exclusive Economic Zone supplies fall outside Central Sales Tax unless the statute is extended by notification.

Goods supplied from Hazira to Bombay High in the Exclusive Economic Zone did not amount to an inter-State sale under the Central Sales Tax Act because Bombay High was treated as outside a State's territory, and the Maritime Zones Act's deeming fiction operated only when the relevant enactment was extended by notification. In the absence of any notification extending the Central Sales Tax Act to the Exclusive Economic Zone, the statutory movement requirement from one State to another was not satisfied, so the transaction was not exigible to Central Sales Tax.

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Issues: Whether the sale of goods to Bombay High in the Exclusive Economic Zone amounted to an inter-State sale or export sale exigible to Central Sales Tax, and whether the Central Sales Tax Act applied in the absence of a notification extending it to that .

Analysis: Bombay High was treated as falling outside the territory of a State, and the Maritime Zones Act was relied upon to distinguish limited sovereign rights over the Exclusive Economic Zone from sovereignty over Indian territory. The deeming fiction under the Maritime Zones Act operates only when an enactment is extended by notification. In the absence of any notification extending the Central Sales Tax Act to the Exclusive Economic Zone, the movement of goods from Hazira to Bombay High did not satisfy the statutory requirement of movement from one State to another under the Central Sales Tax Act.

Conclusion: The transaction was not exigible to Central Sales Tax and the issue was decided in favour of the assessee.

Final Conclusion: The appeal failed and the dismissal of the challenge left intact the view that sales to Bombay High in the Exclusive Economic Zone were outside the Central Sales Tax regime.

Ratio Decidendi: Goods supplied to the Exclusive Economic Zone do not become inter-State sales merely by movement from a State territory, and Central Sales Tax applies there only when the statute is extended by a valid notification under the Maritime Zones Act.

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