In Brief
ABB Ltd., a global engineering company, held a contract with Delhi Metro Railway Corporation (DMRC) to supply power distribution systems and equipment for a metro line. The assessee claimed exemption from Delhi VAT on the basis that the goods were imported from abroad or procured inter-State as required by the contract, thus falling under the Central Sales Tax Act. The tax authorities rejected the claim, but the High Court allowed it after finding that the contract specifications, approved suppliers, inspection requirements, and right of rejection demonstrated that imports and inter-State movement were integral to fulfilling DMRC's contract. The Supreme Court dismissed the revenue appeals, holding that where goods are custom-made for a specific buyer with detailed specifications and inspection rights, such movement is occasioned by the contract and exempt from State VAT.",
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