M/S Rapti Commission Agency vs State Of U.P. & Ors

The Supreme Court upheld the constitutional validity of Section 8-E of the Uttar Pradesh Trade Tax Act, 1948, which mandates tax deduction on purchases, despite the appellant's claim that the transactions were inter-State and thus outside the State's legislative competence. The Court clarified that the High Court's interpretation, which narrowed the application of Section 8-E to intra-State transactions, was valid. The Court emphasized that the appellant, despite not being a 'dealer' under Section 2(c), still had a liability to pay purchase tax under Section 3(1) of the Act, affirming the High Court's decision.