Inter-State sale requires proof of actual movement of goods; quotations alone cannot establish taxable turnover.

Quotations recovered during inspection, without proof of actual sale, movement of goods from one State to another, or delivery to a carrier for onward transport, were insufficient to establish inter-State sales under the Central Sales Tax Act, 1956. The Court held that an inter-State sale requires a sale of goods and an integral nexus between that sale and the movement across State boundaries; mere quotations from business premises do not prove sales suppression or taxable turnover. The Tribunal's contrary view was unsustainable, and the deletion of the disputed turnover by the first appellate authority was upheld.

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Issues: Whether quotations recovered during inspection, without proof of movement of goods and delivery outside the State, could be treated as sales suppression and inter-State sales exigible to tax under the Central Sales Tax Act, 1956.

Analysis: For an inter-State sale under Section 3 of the Central Sales Tax Act, 1956, there must be a sale of goods, movement of those goods from one State to another, and an integral link between the sale and such movement. The material on record did not establish actual movement of goods or delivery to a carrier for onward transport. Mere recovery of quotations from the business premises, without supporting evidence that the quotations fructified into sales, was insufficient to treat the amounts as taxable turnover. The first appellate authority had therefore correctly deleted the turnover and set aside the assessments.

Conclusion: The Tribunal's contrary view was unsustainable. The writ petitions were allowed, the Tribunal's orders were set aside, and the orders of the Appellate Assistant Commissioner restoring deletion of the disputed turnover were upheld.

Ratio Decidendi: Quotation documents alone cannot establish an inter-State sale unless the revenue proves actual sale, movement of goods across State boundaries, and the requisite nexus between the sale and such movement.

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