BAYYANA BHIMAYYA vs THE GOVERNMENT OF ANDHRA PRADESH

The Supreme Court held that under the Sale of Goods Act, 1930, and the Madras General Sales Tax Act, 1939, there were two distinct transactions of sale: one between the Mills and the original purchasers, and another between the original purchasers and third parties. The Court clarified that the delivery order constituted a document of title to goods, allowing for the transfer of rights. Consequently, sales tax was applicable at both points of sale, affirming the tax authorities' decision to levy sales tax on the transactions in question.