THE STATE OF ORISSA AND ANOTHER vs M/s. CHAKOBHAI GHELABHAI AND COMPANY

The Supreme Court held that the determination of where a sale is completed is a factual question, binding the respondent to its admission that sales occurred in Orissa, thus making them liable for sales tax under Section 2(g) of the Orissa Sales Tax Act, 1947. The Court ruled that sales tax authorities are not courts in the strict sense, and fees levied under Rule 59 in conjunction with Section 29(2)(s) of the Act are not taxes but charges for services rendered, affirming the validity of the legislative provisions. The assessment and penalties imposed were upheld as lawful.