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    <title>1986 (3) TMI 304 - KARNATAKA HIGH COURT</title>
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    <description>The definition of &quot;customs frontiers of India&quot; introduced into the Central Sales Tax Act was treated as prospective because it changed the legal content of the taxing expression and lacked clear retrospective effect. Sales of imported cashew to allottees were not sales in the course of import: the Corporation contracted, held the import licence and shipping documents, and retained ownership until customs clearance, while the allottees had no privity with foreign suppliers. The Corporation also acted on its own account, not as agent, and separate bills or markings did not establish unconditional appropriation before shipment. The sales were therefore intra-State taxable sales.</description>
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    <pubDate>Mon, 03 Mar 1986 00:00:00 +0530</pubDate>
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      <title>1986 (3) TMI 304 - KARNATAKA HIGH COURT</title>
      <link>https://www.taxtmi.com/caselaws?id=126760</link>
      <description>The definition of &quot;customs frontiers of India&quot; introduced into the Central Sales Tax Act was treated as prospective because it changed the legal content of the taxing expression and lacked clear retrospective effect. Sales of imported cashew to allottees were not sales in the course of import: the Corporation contracted, held the import licence and shipping documents, and retained ownership until customs clearance, while the allottees had no privity with foreign suppliers. The Corporation also acted on its own account, not as agent, and separate bills or markings did not establish unconditional appropriation before shipment. The sales were therefore intra-State taxable sales.</description>
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