Inter-State transit exemption under sales tax law cannot be denied by adding a time limit or constructive delivery rule.

Section 3 of the Central Sales Tax Act deems inter-State movement to continue until delivery is taken from the carrier, and that statutory scheme does not permit authorities to impose a separate time limit for collection of goods. Section 6(2) exemption for subsequent sales during movement cannot be curtailed by treating retention beyond an administratively fixed period as constructive delivery. Section 51 of the Sale of Goods Act did not aid the revenue because there was no material showing the carrier held the goods on the buyer's behalf. The Court reaffirmed that, in taxing statutes, no extra words may be read in to enlarge the charge or narrow the exemption, so the revenue's appeal failed.

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Issues: Whether the authorities could deny exemption under Section 6(2) of the Central Sales Tax Act, 1956 by prescribing a time limit for taking delivery from the carrier and treating retention beyond that period as constructive delivery terminating inter-State transit.

Analysis: Section 3 of the Central Sales Tax Act, 1956 deems movement of goods delivered to a carrier to commence on such delivery and to terminate when delivery is taken from the carrier. The provision contains no temporal qualifier permitting the tax administration to superimpose a fixed period for taking delivery. Section 6(2) exempts subsequent sales effected by transfer of documents of title during movement, and the statutory scheme does not authorise the Commissioner to introduce a concept of constructive delivery to cut down that exemption. Section 51 of the Sale of Goods Act, 1930 was also examined, but it did not assist the revenue because there was no material of acknowledgment by the carrier that it held the goods on behalf of the buyer. In a taxing statute, no additional words can be supplied to enlarge the charge or narrow the exemption.

Conclusion: The time-limit based approach and the doctrine of constructive delivery could not be used to deny exemption under Section 6(2) where the statutory conditions were otherwise satisfied.

Final Conclusion: The appeals raised by the revenue failed, and the High Court's view in favour of the assessee was left undisturbed.

Ratio Decidendi: Where a taxing provision deems inter-State transit to end only on delivery from the carrier, the tax authority cannot prescribe a separate time limit or apply constructive delivery to terminate transit and deny the statutory exemption.

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