Inter-State sale of natural gas through a common carrier pipeline was confirmed, defeating Uttar Pradesh VAT jurisdiction.

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....Natural gas supplied under the GSPA was held to be an inter-State sale concluded at Gadimoga in Andhra Pradesh, where delivery, measurement, title and risk passed to the buyer's designee; the subsequent movement through a common carrier pipeline into Uttar Pradesh was only transportation and did not convert the transaction into an intra-State sale. Co-mingling, re-metering, fungibility and processing during transit did not alter the sale's character, and Uttar Pradesh therefore lacked jurisdiction to levy VAT. Explanation 3 to Section 3 of the CST Act was treated as clarificatory, reflecting the pre-existing legal position and applying to the original scheme of the provision.....