M/S Mitsubhishi Corporation vs State Of Karnataka & Ors

The Supreme Court held that the transaction in question must be classified as an interstate sale under Section 3(a) of the Central Sales Tax Act, 1956. The Court emphasized that the assessee failed to exhaust the appeal provisions under Section 20 of the Karnataka Sales Tax Act, 1957, before seeking judicial intervention. Consequently, the Court restored the order of the learned Single Judge, directing the assessee to file an appeal under the 1957 Act, and mandated that the appeal be decided on merits without pre-deposit within two months.