In Brief
The Supreme Court held that tax authorities cannot impose arbitrary time limits for when goods must be collected from a carrier to deny inter-state sales tax exemption. Under the Central Sales Tax Act, 1956, inter-state movement of goods terminates only when actual physical delivery is taken from the carrier—not upon an administratively-determined 'constructive delivery' after 10 or 30 days. The Court struck down circulars imposing such time limits as ultra vires, holding that taxing statutes must be read strictly without adding conditions the legislature omitted. Only Parliament can amend the law; tax administrators cannot rewrite it through orders or circulars."
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