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The Tata Iron & Steel Co., Ltd vs The State Of Bihar on 19 February, 1958

It was not said in the case of Tata Iron and Steel Co. Ltd. v. The State of Bihar [1958] S.C.R. 1355 which was a case of control, that there was no sale. The entry should be interpreted in a liberal spirit and not cut down by narrow technical considerations. The entry in other words should not be shorn of all its content to leave a mere husk of legislative power. For the purposes of legislation such as on sales lax it is only necessary to see whether there, is a sale express or implied. Such a sale was not found in forward contracts and in respect of materials used in building contracts. I am of opinion that in these transactions there was a sale of sugar for a price and the tax was payable".
Supreme Court of India Cites 45 - Cited by 303 - Full Document

State Of Andhra Pradesh vs Abdul Bakhi And Bros on 8 April, 1964

It was contended that the factory was a manufacturer of sugar and paid excise duty on sugar to the Central Government and sugar was item 34 of the Second Schedule and therefore no tax was payable by a dealer who is a manufacturer of sugar. The purchase of sugarcane was said to be for manufacture of sugar and not for resale of sugarcane and therefore the tax which is levied on the dealer will not fall on the appellants on the purchase of sugarcane. The High Court held relying on the decision of this Court in State of Andhra Pradesh v. Abdul Bakshi & Bros. A.I.R. 1965 S.C. 531 that if a person carries on the business of buying or selling a commodity it is not necessary that he should sell the same commodity to become a dealer. The commodity may be converted into another saleable commodity or it may be used as an ingredient in the manufacture of a commodity. Therefore, the factories which bought sugarcane could be said to carry on the business of buying and selling sugarcane and the factories are dealer within the meaning of the Mysore Sales Tax Act. The third contention on behalf of the appellants was that the levy of 15 per cent purchase tax on the sugarcane on the appellants was in violation of Article 14 of the Constitution inasmuch as the rates were different in different States. It is an indisputable feature in the present appeals that all the factories in Mysore have been treated equally. Different rates in different States are explicable on various grounds. The quantity available, the conditions of agriculturists, the number of factories will all have distinctive features. Therefore, there can be no infraction of Article 14 of the Constitution. It was also said on behalf of the appellants that tax on purchase of sugarcane could not be collected by the appellants as tax.
Supreme Court of India Cites 3 - Cited by 145 - J C Shah - Full Document

M/S New India Sugar Mills Ltd vs Commissioner Of Sales Tax, Bihar on 26 November, 1962

The decision of this Court in the case of Gannon 238 Dunkerley & Co. (supra) was referred to in the New India Sugar Mills (supra) case for the meaning of the word 'sale). The majority view in the case of New India Sugar Mills Ltd. was on the reasoning that the prerequisite to a sale was a contract of sale which was to be had between the parties. The Province of Madras intimated its requirements to the Controller. The Controller called upon the manufacturing units to supply sugar to the Province. It was held that the Controller did not act as an a,-lent of the Province to purchase goods but that he acted in exercise of his statutory authority. Therefore, there was no offer by the Province to purchase sugar and there was no acceptance of offer by the manufacturer. The ratio was that there was no privity between the manufacturer and the Province. The minority view in that case was that there might be compulsion in both buying and selling but a compelled sale might nevertheless be a sale. Hidayatullah, J. for the minority view said "the affairs of the world are very complicated and sales are not always in their elementary forms. Due to short supply or maldistribution of goods, controls have to be imposed. There are permits, price controls, rationing and shops which are licensed. Can it be said that there was no sale because mutuality is lost on one account or another ?
Supreme Court of India Cites 32 - Cited by 190 - J C Shah - Full Document
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