Agency in CNG distribution makes outlet operators commission agents, rendering taxable Business Auxiliary Service rather than purchasing goods for resale.

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....Agency in CNG distribution depends on the agreement read as a whole, particularly whether title, risk and control over the goods pass to the distributor. A sale requires transfer of property in goods for a price, whereas an agent facilitates the principal's sale and accounts within the principal's control. Where the supplier retains control over CNG supply, equipment, retail price, inspection and unsold stock, outlet operators providing infrastructure and personnel act as commission agents rather than buyers. Remuneration linked to quantities sold is commission for Business Auxiliary Service, not a trade discount, where the arrangement is not principal-to-principal.....