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State of Gujarat Versus Ahmedabad Jilla Sahkari Doodh Utpadak Sangh Ltd.

2017 (7) TMI 463 - GUJARAT HIGH COURT

Whether on facts and circumstances of the case, the Tribunal has rightly held that the transactions in question are consignments or interState transactions and thereby the opponent is entitled to exemption under Section 6A of the Central Sales Tax Act? - Held that: - Consignment Agreement’s clause 4 was pressed into service to contend that since the entire sales proceeds were paid immediately and the risk in goods was entirely that of the agent sale was a local sale. Moreover, the Ghee / But .....

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rmissible. - Whether the actual movement of goods did take place? - Held that: - the State did not produce any other statements and the Tribunal was therefore right in holding that in probability if other statements were produced it could have disclosed the true nature of transactions of consignment. Since the inquiries visavis these transporters was held behind the back of the assessee, such facts cannot be relied upon by the Revenue. Moreover all such statements related only to one transpo .....

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sfer of goods was in course of interState sale. From the facts on record, that forms ‘F’ for the assessment periods in question were produced, is not disputed. The claim was not disallowed by the assessing authority on the ground that such ‘F’ forms were not produced. The contention that the forms were defective was also taken at the stage of the Second Appeal. The Tribunal, in such circumstances recorded a finding of fact that, 15 years after the transactions having taken place, the plea of pro .....

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AND MR. BIREN VAISHNAV, JJ. For The Appellant : Mr. Pranav Trivedi, Assistant Government Pleader For The Opponent : Mr B S Patel with Mr Chirag B Patel, Advocate CAV JUDGMENT (PER : HONOURABLE MR.JUSTICE BIREN VAISHNAV) 1 All these appeals filed under Section 78 of the Gujarat Value Added Tax Act, 2003, ( Value Added Tax for short) are against the common judgement and order dated 21.03.2013 passed by the Gujarat Value Added Tax Tribunal, Ahmedabad. By the aforesaid order, the Tribunal rejected .....

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disposed of the clarification applications with the aforesaid observations, the State of Gujarat has come in appeal against the common judgment and order passed in Second Appeal Nos 622 to 624 of 2002 rendered by the Tribunal on 02.04.2011. 2 By an order dated 29.11.2013, the appeals were admitted to consider the following substantial question of law: Whether on the facts and circumstances of the case, the tribunal has rightly held that the transaction in question are consignments or interstate .....

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nment agents, Ghee and Butter was transported and sold at Silvassa and / or Daman. It was the case of the assessee that such consignee agents, swould lift the goods from the factory premises of the principal (the dairy) for the purposes of sale to Silvassa / Daman. These consignee agents would on lifting such goods would deposit an advance popularly known as Ghee deposit or butter deposit in the principal s favour. On the receipt of sale notes from the consignee agent, who would sell such goods .....

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to another by the reason of transfer of such goods through the agent. Since the goods were sold outside the State at Daman and Silvassa which had a holiday period declared by the Central Government, tax exemption would then be sought by the assessee. 4 The Assessing Authority i.e. the Assistant Commissioner of Sales Tax was of the opinion that such sales through consignee agents were in fact not inter State transactions but were local sales and therefore not eligible for exemption under Section .....

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; 9,69,115/under Section 45 and 49(2)(C) respectively of the Gujarat Value Added Tax. The Assessing Authority held that the assessee was liable to pay ₹ 1,10,66,672 as tax since the assessee had already paid ₹ 23,85,149/the liability was assessed at ₹ 86,81,523/The Assessing Authority in coming to the conclusion that the assessee was in fact not engaged in inter State sales but local sales, based its opinion on certain factors namely: (A) that a Ghee Deposit Account was opened .....

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emit the sale proceeds to the union immediately after effecting the sales along with account sales. The consignee can sell the goods on cash or credit basis at his own risk. (B) Based on (A) above the Assessing Authority was of the opinion that since the consignment agent lifted the goods from the dairy itself, the sale in fact took place at the outlet itself as the delivery was taken by the consignee at his own risk. Therefore the transaction of sale was complete at the dairy and therefore it w .....

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ish Trading Company. A statement was recorded on 25.09.1998 of one Narsinhbhai Lallubhai Damania, the owner of the Company. In such statement, the owner of the trading company stated that the godown of the agency was never used for transportation of goods as a consignee agent for transportation of the assessee s products to Daman and that the agency had never operated as a consignee agent for transportation of goods such as ghee and butter to Daman. The Assessing Authority, therefore, based on s .....

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iled a first appeal before the Deputy Commissioner of Sales Tax under Section 65 of the Gujarat Sales Tax Act, 1969. Before the Appellate Authority, the assessee assailed the decision of the Assessing Authority and contended that the findings of the Assessing Authority that it was not an inter State transfer but local sale was wrong. It was contended by the assessee that the goods in fact were transported to Silvassa and Daman and forms F were produced before the prescribed authority in support .....

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ation of Ghee and Butter to Silvassa to substantiate inter State movement, production of sale notes to show that the ghee deposit account would not tantamount to acceptance of full sale price of goods by the dairy merely because of such full payment. Further evidence in the form of proforma invoices F forms and details of vehicles through which such goods were in fact inter State transactions were produced. The Appellate Authority also did not agree to the assessee s transactions based on the co .....

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6.2002. 6 Aggrieved by this order of the Authorities below, the assessee dairy approached the Gujarat Value Added Tax Tribunal by filing Second Appeals, the judgments of which, are under challenge in these Tax Appeals. The Tribunal in the impugned judgment accepted the contention of the assessee holding that the dairy through its consignee agents sold goods to sellers in Silvassa / Daman. The goods in question namely butter and Ghee were transported to the sellers in Daman and Silvassa and hence .....

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posit account known as Ghee deposit account or butter deposit account was opened in the books of the assessee, such device of accepting advance deposit would not tantamount to accepting full sale price of goods. Such deposit, according to the tribunal was in the nature of an advance deposit and therefore the findings of the First Appellate Authority and the Assessing authority that merely because such consignee agents paid the full price to the principal prior to dispatch of goods and such goods .....

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vehicle owners which transported the goods, the Tribunal upheld the contention of the assessee. While allowing the appeal, the Tribunal observed and accepted the submissions of the assessee that sales through the consignee agents and consequential transportation of goods through such agents for sale to Silvassa and Daman was transfer of such goods and its movement from one State to another through its agent and therefore exempt from tax. 7 In order to appreciate the correctness of the findings .....

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and that the consignee can sell the goods on cash or credit basis at his own risk, the sale in fact occurred at the dairy and was therefore a local sale, and assessable to tax and not exempt as contended by the assessee. B) The fact that the entire payment of the sale proceed was made in advance by the principal was a circumstance against the assessee to contend that the sale was in the nature of inter State transaction. C) Further it was contended that in absence of any accounts produced to sub .....

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discussion in the judgment of the Tribunal, Mr Pranav Trivedi, learned AGP invited the attention to the details, which were produced at pages (831 to 841 of the paper book before the original authority). In the body of the judgment of the Tribunal statements have been reproduced relating to five vehicles belonging to one of the commission agents namely Bandish Trading Company. Attention is invited of this Court of such statement made by the owners of such transport vehicles recorded during the .....

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ct stipulates that where any dealer claims that he is not liable to pay tax under this Act in respect of any goods, on the ground that the movement of such goods from one State to another was occasioned by a reason of transfer of such goods by him to any other place or to his agent or principal, the burden of proving that such movement of goods did occur is on that dealer. A declaration in the nature of form F has to be produced by the dealer to substantiate his transaction of inter State moveme .....

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lifting of the goods by the consignee at the dairy and subsequent exposure to such goods at his own risk would not render such a sale in one as a local sale. B) Merely because the accounts of the dairy showed an advance payment as Ghee deposits / butter deposit such advance receipt would not tantamount to payment of consideration in advance. Sale notes were produced by the consigne based on which the Ghee deposit account would be debited against such advance deposit. Such a deposit and the adjus .....

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onclusion that the sale was not inter State sale. E) Substantial evidence has been produced by way of lorry receipts to show that the assessee transported goods from Ahmedabad to Silvassa through the consignment agents which were carried through the vehicles. Detail of the vehicles which carried such goods according to Shri Patel has been produced extensively in the paper book and has been reproduced by the Tribunal. According to Mr Patel, the statements which are sought to be relied upon, five .....

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en of proof and in accordance with Section 6A of the Central Sales Tax Act have proved that the sales were in fact inter State and not local sales. It was not open for the assessing authority to contend now that such forms were defective and therefore cannot be taken into account for discounting the assesses s version that the sales were in fact inter State. 9 It is in light of the submissions made that the correctness of findings of the Tribunal need to be examined in the facts of the case on h .....

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s were made. According to the assessee, once sales notes were furnished adjustments were made. Their books of account would reflect stock transfer. What the revenue found objectionable and therefore leading it to conclude that the sales were local sales and not intraState have been discussed in the respective stands of the parties. Primarily, two issues were before the Tribunal, which it answered. (A) Whether the device of sale through such consignment agreements entered into by agents and the c .....

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lar transport carriers, the L/R shows the name of the appellant as the consignor of the goods . The commission agent is shown as consignee and when the transporters deliver the goods to them, the commission agent put their signatures on the transport receipts for having received thegoods. Therefore, it is incorrect to say that the goods have been delivered to the consignee as agent at the appellant s factory. In the Tribunal s view, details of the transport company receipts through which goods w .....

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ods on their own account and their books as well as income tax returns only disclosed the earning of commission as the selling commission agents of the appellant. 48 Based on such sale notes, the net realization shown therein has been credited by the appellant to the Ghee sale account . Butter sale account. Thus, all these expenses are reflected in sale account. They are borne by the appellant. Whatever expenses including telephone and postage, incurred by the agent are shown deducted in their s .....

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not show the expenses, the sales on consignment basis cannot be accepted. The lower authorities have failed and neglected to appreciate that the amount taken to the sales account is the amount of net realization and not gross realization. Therefore, the question of debiting expenses does not arise. The lower authorities have erroneously taken the advance received as sales without taking into consideration the fact that such advance received is first taken to the deposit account and not to the sa .....

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t the enforcement branch of Ahmedabad had already visited their place and their godown in Silvasa. 50.1 The Tribunal has also considered following admitted facts which have been stated by the appellant. The Tribunal has also accepted the said facts as correct because they are based on documentary evidence produced by the appellant on the record of the case. The appellant has also produced proof by way of affidavits of the parties who had issued such transport receipts as well as copies of agreem .....

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said commission agents were produced to show that they had sold the goods as selling commission agents. It is also admitted that the said parties are registered outside the State in the Union Territory and they are also assessed in respect of those transactions in their respective territory. Even visits were paid and it was found that the parties do have their places of business at the respectiveplaces. Therefore, on facts, the conclusion that those parties at Daman and Silvasa have not acted as .....

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nsportation charges and others expenses in that behalf. 51 The Tribunal is of the view that the lower authorities have also incorrectly equated the amount advance payment as the sale price of the goods. The lower authorities have also been wrongly impressed by the fact about insurance having not been taken. The authorities have further wrongly observed that the goods were delivered to the buyer in his own vehicle. This conclusion arrived at by the lower authorities in the Tribunal s view, is tot .....

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conclusion that (1) the said parties have not acted as selling commission agents and (2) the goods have not gone outside the State, are totally contrary to and inconsistent with the evidence on record. Theauthorities have failed and neglected to appreciate that admittedly at the time of visit, the parties did not have their place of business, though they were closed at the time of visit. Not only that, but the said conclusion suffers from the vice of nonapplication of mind on the part of the aut .....

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ribunal s view, the conclusion of the authorities below are vitiated and arrived at without properly appreciating the evidence produced by the appellant and, therefore, the conclusions reached on facts as well as on law to the effect that M/s. Bandish Trading Company has not acted as selling commission agent and that he had taken delivery of the goods locally and the goods have bot been dispatched to the other State are wholly erroneous. There is no specific denial about the transaction of consi .....

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oods in Daman / Silvasa as per Rules 3(C), 7 and 8 of CST (Gujarat) Rules, 1970 along with form F which were obtained from prescribed authority of that State. Not only that, but it is proved that all the four consignment agents were assessed in Daman /Silvasa by the sales tax authority. In that view of the matter, the conclusion and reasoning to treat local sales by agent are against the evidence. 58.1 In this connection, the revenue has produced statement of owner of five vehicles to prove that .....

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ppellant and used the said information against the appellant, and therefore, the reasoning for considering consignment sales as local sales is unjustified. In Tribunal s view, the statement of the owner of vehicles was recorded at assessment stage, but copy thereof was not given to the appellant and for the first time copy of statement and information obtained recently from the RTO are given to the appellant at second appeal stage, and therefore, without affording any opportunity of cross examin .....

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nce to show that goods were transported from Ahmedabad to Silvasa. 60 In view of the above facts, the Tribunal is of the view that if the department had made cross check with vehicle owners, the department must have recorded statement of all the vehicle owners. However, the State Government agent has produced only five statements of owners of vehicles. 62 In Tribunal s view, after production of forms in 1999 by the appellant at assessment stage, for the first time after the lapse of about 15 yea .....

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down in the case of E.V.Mathai and sons (129 STC 503, paper book page 125) that if forms are defective, then, opportunity of correction has to be provided to the dealer. In the Tribunal s view, it is now not possible to cure the defect in the forms after about 15 years as the business of consignment agent is closed down since long. The claim of consignment sales cannot be disallowed as production of Form F was not mandatory during the years 1996-97, 1997-98 and part of year 1998-99 i.e. from 1.4 .....

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s but same are covered by section 6A of the CST Act and, therefore, not liable to tax under Local Act in the facts and circumstances of the case. They are interState sales u/s. 3(a) of CST Act and as such, are not liable to tax under the Local Act in the facts and circumstances of the case. 10 Analysis of the evidence on record, in the facts of the case had led the Tribunal to arrive at a conclusion that it did. The findings and the conclusions arrived at need to be assessed in light of the ques .....

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t of such goods from one State to another was occasioned by reason of transfer of such goods by him to any other place of his business or to his agent or principal, as the case may be, and not by reason of sale, the burden of proving that the movement of those goods was so occasioned so occasioned shall be on that dealer and for this purpose he may furnish to the assessing authority, within the prescribed time or within such further time as that authority may, for sufficient cause, permit, a dec .....

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atisfied after making such inquiry as he may deem necessary that the particulars contained in the declaration furnished by a dealer under subsection (1) [are true and that no interState sale has been effected, he may, at the time of, or at any time before, the assessment of the tax payable by the dealer under this Act, make an order to that effect and thereupon the movement of goods to which the declaration relates shall, subject to the provisions of subsection (3),] be deemed for the purpose of .....

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ce to contend that since the entire sales proceeds were paid immediately and the risk in goods was entirely that of the agent sale was a local sale. Moreover, the Ghee / Butter deposit advance when seen in light of this and deduction and set off of expenses showed / suggested local sale. The Tribunal, on facts found that, in the book of commission agents stock transfers are shown and when sold at Silvasa sales are shown in the returns submitted to the Sales Tax Office at Silvasa / Daman. Further .....

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in the circumstances of the case the transactions in dispute for both the periods, between the opponent firm and theparties at Delhi, who according to the opponent firm are its commission agents, were transactions of consignments of goods to these commission agents for sale on commission basis or were transactions of sales effected by the opponent firm to the said commission agents, that is, sales by principal to to principal. Further it was held that: 28 It was next contended that the Hundis w .....

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r which the sales were effected but the very fact that the amounts of Hundis approximated with the sale price of the goods despatched, again goes to emphasis the type of relationship which generally obtains between a principal and its agents. If ultimately the Delhi constituents of the assessee were to render a true and full account of the transactions it would not matter if the assessee received only an approximated amount towards these transactions. 29 From this discussion it follows that ther .....

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lhi constituents of the assessee. As already noted above if the Delhi constituents of the assessee had become the owners of the goods despatched to them they would have surely not considered themselves liable to account for any of the expenditure incurred by them after taking delivery of the goods in question. It is however found that these Delhi constituents have made the following expenditures after taking the delivery of the goods and have debited this expenditure to the account of the assess .....

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after taking the delivery of the consigned goods is apparent from the various statements of accounts sent by these constituents to the assessee at different times. One of such statements is found at the page 177 of the paper book. Apart from showing that these Delhi constituents of the assessee had notbecome the owners of the goods despatched to them these items of the expenditure further reveal the fact that that these Delhi constituents were considering themselves liable to render the account .....

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accountable to the assessee after taking the delivery of the goods and upto the state, these accounts were approved by the assessee, either expressly or impliedly. 30 The above discussion thus reveals two important aspects of the matter namely (1) the property in the goods despatched by the assessee to Delhi did not pass to the Delhi constituents and (2) the Delhi constituents remained accountable to the assessee for all the receipts and the expenditure made by them with reference to the goods .....

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the sale, when in fact there was movement of goods. In the case before it the Supreme Court, held that in order to hold a sale to be inter30 38 State sale, the contract may not provide for such movement but if such movement is incidental then such sale would be interState sale. The Supreme Court in the case of Union of India and Another vs. M/s. K G Khosla & Co. Ltd., and others (Supra) held as under: 15 It is true that in the instant case the contracts of sales did not require or provide th .....

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and (b) of Section 3 of the Act are mutually exclusive and that Section 3(a) covers sales in which the movement of goods from one State to another is the result of a covenant or incident of the contract of sale, and property in the goods passes in either State (page 391). Sarkar,J. Speaking for himself and on behalf of Das Gupta, J. agreed with the majority that clauses (a) and (b) of Section 3 are mutually exclusive but differed from it and held that a sale can occasion the movement of the goo .....

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t to reconsider thequestion but the Court declined to do so. In a recent decision of this Court in Oil India Ltd., v. The Superintendent of Taxes, it was observed by Mathew, J., who spoke for the Court, that: (1) a sale which occasions movement of goods from one State to another is a sale in thecourse of interState trade, no matter in which state the property in the goods passes; (2) it is not necessary that the sale must precede the interState movement in order that the sale may be deemed to ha .....

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ontract of sale, then the sale is an interState sale. Even considering the judgement in the case of State of Gujarat vs. Bombay Metal Alloys reported in (54 STC 45) the Tribunal held that merely because the contract of sale does not provide for occasion of movement, would not itself go against the assessee. The relevant paragraph of which is as here under: 18 Taking an overall view of the material facts and circumstances of the case in their proper perspective, the conclusion is inevitable that .....

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umulatively indicate that the movement of goods herein satisfies the said test. The buyer, who carried on business in another State and for whom the instant transaction was a sole business venture within the territory of this State, had instructed the vendor after the conclusion of the contract of sale, but before the title to the goods passed, to despatch the goods toBombay. Pursuant to such instructions, the goods were separated by the vendors as consignors. The buyer, who was the consignee, h .....

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on 15 of the Act. 11.2 The other question that the Tribunal addressed is on the question whether the actual movement of goods did take place? It is the case of the assessee that movement of goods from one State to another State did take place. Such transfer was occasioned through his consignee agents. In order to substantiate the facts of movement of goods and to show that the goods were in fact dispatched through regular transport carriers, Lorry receipts were produced to show movement of goods .....

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o. 11 18 447 Patel Enterprise 22 24 455 Bandish Trading Co. 28 34 463 Patel Enterprise 6 8 469 Bandish Trading Co. 35 41 477 Total 113 140 The revenue for the first time in the course of hearing before the Tribunal, produced statement of five transporters who had either, denied transporting the consignment or the vehicles had for less load bearing capacity then the weight of the goods consigned. All these statements of such transporters were recorded during the disputed assessment period. The co .....

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aring before the Tribunal. As rightly observed by the Tribunal, not only were these cases produced for the first time and copies thereof were not given to the assessee. Such statements, as the Tribunal had rightly held, could not have been relied upon at the stage of Second Appeal without affording any opportunity of crossexamination. Moreover, except these five sample statements the State did not produce any other statements and the Tribunal was therefore right in holding that in probability if .....

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