Nut Crackers

Questions & Answers Indirect Taxes

C. B. Thakar, Advocate


Issues in Inter-state transfer

  1. Q.1. A dealer transfers goods from Maharashtra to his site in Gujarat State and fabricates the materials to be used in the contract at such place. The issues are as under:
    (i) Whether the dealer will be required to obtain ‘F’ form for such transfer.
    (ii) Whether he can get registration in Gujarat though he has no place of business in Gujarat.
    (iii) Whether above transfer can be liable to CST in Maharashtra as well as local tax in Gujarat?

    Ans. The issues are required to be seen in light of provisions of section 6A and the principles of inter-state sales contained in section 3(a) of CST Act, 1956.

    Section 6A of CST Act, 1956 reads as under.

    “6A. Burden of proof, etc. in case of transfer of goods claimed otherwise by way of sale. – (1) 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 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 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 declaration, duly filled and signed by the principal officer of the other place of business, or his agent, or principal, as the case may be, containing the prescribed particulars in the prescribed form obtained from the prescribed authority, along with the evidence of despatch of such goods and if the dealer fails to furnish such declaration, then the movement of such goods shall be deemed for all purposes of this Act to have been occasioned as a result of sale.”

    Thus if the transfer is to the place of business of the dealer then ‘F’ form is required. The term ‘place of business’ is defined as under, in section 2(dd) of CST Act, 1956.
    “[(dd)”place of business” includes –

  1. in any case where a dealer carries on business through an agent (by whatever name called), the place of business of such agent;
     

  2. a warehouse, godown or other place where a dealer stores his goods; and
     

  3. a place where a dealer keeps his books of account;]”

The term ‘warehouse’ is further defined in Rule 2(e) of CST (R & T) Rules, 1957 as under.

“(e) ‘warehouse’ means any enclosure, building or vessel in which a dealer keeps a stock of goods for sale.”

It can be seen that storing of goods for sale is also a place of business. When the materials transferred to the site are fabricated into finished goods for use, it can be said that there is storing of goods for sale. As such it becomes the place of business.

The transfer of goods will thus be considered to be at place of business, requiring ‘F’ form.

Normally in every State there is facility of granting Registration on Non Resident basis; i.e., on the basis of address in other State.
A registration can be obtained on above basis on Maharashtra address.

For an inter-State sale the movement of the goods should be of the same goods which are subject matter of sale. This position is clear from provisions of section 3(a) of CST Act read with catena of judgments. Attention can be had to judgment of Supreme Court in Sahaney Steel & Pressing Works (60 STC 301)(SC). On given facts it appears that the raw materials are being transferred to site where the finished goods, to be used in contract, will be manufactured.

Under above circumstances there is no movement of goods from Maharashtra which are subject matter of sale and hence the question of attracting section 3(a) does not arise. The transfer is branch transfer, not liable to tax in Maharashtra, subject to production of ‘F’ form. The sale will be local sale in Gujarat.

Inter-state Works Contracts

  1. The works contractor in Gujarat has a contract outside the State; i.e., in A.P.. The dealer effects purchases in A.P. and uses there in the contract. However dealer transfers his equipments and machineries from Gujarat to A.P. for use in execution. After the work is over the above equipments are retransferred to Gujarat. Whether ‘F’ form formalities are required in relation to above transfers.

    Ans. The reply again depends upon the provisions of section 6A of CST Act, 1956. The said section is already reproduced above. It can be seen that the section has not distinguished between the nature of goods transferred. There is no warrant to say that for transfer of capital goods, ‘F’ form is not required. The section suggests that any transfer of goods to other State, if not supported by ‘F’ form, will be deemed to be sale. Therefore even for transfer of capital goods also the ‘F’ form formalities will be necessary.

Inter-state Branch Transfer

  1. The H.O. in Maharashtra dispatches goods to his place of business in M.P.. However the branch is not in position to issue ‘F’ form to H.O. and hence the transfer is going to be deemed as inter-State sale as per section 6A. Whether the legislature has power to deem such transfers as inter-State sale? If yes, whether the branch can issue ‘C’ form so as to lower the liability to tax?

    Ans. The issue is very pertinent. Under CST Act the Parliament has power to levy tax on ‘sale’. The meaning of sale is well understood by number of judgments including Gannon Dunkerly & Co. (9 STC 353). In light of above judgments, unless there are two separate entities as seller/purchaser no sale transaction can take place. Therefore apparently on branch transfers the Parliament cannot levy tax under CST Act, 1956, there being no sale as per statutory meaning. Under Constitution by separate entry in List I, the Parliament has power to levy tax on consignments also. However the said power is separate and Parliament can exercise the same by enacting a separate Legislation for said purpose. When tax is sought to be levied on branch transfers, as deemed sale, in my opinion, the said levy is not Constitutional. However till the law is challenged and the position is got clarified from proper courts, the above section will be a binding section and the transactions will be deemed to be sale in absence of ‘F’ form.

    The next issue is about receipt of ‘C’ forms. As clear from the above section 6A on failure to produce ‘F’ form the transaction is deemed to be sale.

    The deemed provisions bring the transaction at par with any other normal sale transactions and all the incidents of sale will get attracted here also. Like a normal sale can be effected against ‘C’ form, this deemed sale can also be against ‘C’ form. Accordingly ‘C’ forms received from branch can be valid for such deemed sales.

Registration across the State

  1. The dealer was not registered in other State when he transferred the goods to such state. He got registration subsequently and obtained ‘F’ forms. Can the dealer issue ‘F’ form even for the transfers which have taken place prior to such date of registration.

    Ans. The provisions regarding issue of ‘F’ forms, are not like ‘C’ form. In case of ‘C’ form it is necessary that the dealer, willing to issue ‘C’ form, should be a registered dealer at the time of purchase though ‘C’ form may be issued subsequently. ‘F’ form only requires that it should be issued by a registered dealer. However there is no requirement that on date of transfer he should be a registered dealer.

    Under above circumstances, ‘F’ form can be issued even for unregistered period. The above position is also duly settled by Madras High Court in case of State of Tamil Nadu vs. Cocoa Products & Beverages Ltd. (109 STC 634)(Mad). In that case Hon. Madras High Court has held that the ‘F’ form can be issued even for unregistered period also. In view of same the ‘F’ forms can be issued for transfers which have taken place prior to date of registration.