Inter-State sale classification prevails where goods move on customer orders through branches and the branch acts only as a conduit.

Goods dispatched against specific customer orders through branch offices were treated as inter-State sales because the movement was occasioned by the contract of sale, not as a mere stock transfer under section 6A of the Central Sales Tax Act, 1956. The branches acted only as conduits between the manufacturer and customers, and invoices were raised on the customers pursuant to pre-existing work orders. The presence of branch routing did not alter the character of the transaction. The writ challenge to the revisional assessment failed, and the assessment treating the turnover as inter-State sales was sustained.

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Issues: Whether the movement of goods from the manufacturing unit to the branches was a stock transfer exempt under section 6A of the Central Sales Tax Act, 1956, or an inter-State sale taxable under section 3(a) of that Act.

Analysis: The goods were manufactured against specific customer orders communicated through the branches, with invoices raised on the customers and dispatches made pursuant to the pre-existing work orders. The branches functioned only as conduits between the manufacturer and the customers, and the movement of goods was occasioned by the contract of sale. In such a situation, the fact that the goods passed through branches did not convert the transaction into a mere stock transfer.

Conclusion: The movement of goods was held to be an inter-State sale and not a stock transfer; exemption under section 6A was unavailable.

Final Conclusion: The writ challenge to the revisional assessment failed, and the assessment treating the turnover as inter-State sales was sustained.

Ratio Decidendi: Where goods are dispatched pursuant to specific customer orders and the branch office acts only as a conduit, the movement of goods from one State to another is occasioned by the contract of sale and is taxable as an inter-State sale, not as a mere stock transfer.

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