UNION OF INDIA vs CENTRAL INDIA MACHINERY MANUFACTURING CO. LTD. & OTHERS

The Supreme Court held that under the Rajasthan Sales Tax Act, 1954, the transfer of property in goods is essential for a sale to occur. The Court clarified that the raw materials purchased by the Company against 90% advance payment did not become the property of the Railway Board, as the advance was for the contract price of the wagons, not the materials. The appeal was dismissed, affirming that the materials remained the property of the Company until the wagons were completed and delivered.