ORDER DEEPAK VERMA J. - Heard Sri Indrakumar, learned counsel for Sri E. I. Sanmathi for the petitioner. Perused the records. This revision is at the instance of the assessee under section 23(1) of the Karnataka Sales Tax Act, 1957 (hereinafter shall be referred to as, "the KST Act") against the order dated October 26, 2006, passed by the Karnataka Appellate Tribunal, Bangalore in STA. Nos. 2316-2317 of 2004 which were also preferred by the assessee herein against the orders of Joint Commissioner of Commercial Tax, Appeals, Bangalore Division against the order dated June 29, 2004, for the assessment years 1999-2000 and 2000-01 under the KST Act. The brief facts for deciding the said revision are mentioned hereunder : The assessee is the authorised dealer to Toyota light motor vehicles. Being the dealer, it is purchasing vehicles from M/s. Toyota Kirloskar Motor Limited, Bangalore, for delivery of the vehicles to its respective customers. The business premises of the assessee were inspected on January 3, 2002 and September 9, 2002. During the course of inspection certain documents and books of account were seized. After processing the same and verifying the documents, it was revealed to the Revenue that the assessee is disguising its inter-State sales as local sales and evading tax on inter-State sales by claiming these as tax-paid second sales. Show-cause notice therefore was issued to the assessee under section 28(6) of the KST Act and it was proposed to levy Central sales tax on the inter-State sales of vehicles for the aforesaid assessment years. Against the provisional assessment notices, the assessee had filed objections and vehemently disputed levy of Central sales tax. Throughout the pleadings of the assessee were that the sale had taken place at Bangalore. The delivery of the vehicle was also given to its various customers at Bangalore and therefore, the rigours of inter-State sale were not attracted. However, despite this ACCT discussed objections, rejected them and confirmed the levy of Central sales tax in provisional assessment orders. Aggrieved by the provisional assessment orders, the assessee was constrained to file appeals before the first appellate authority who also after examining the matter from all angles, came to the conclusion that there was no substance in the assessee's appeals, which were accordingly dismissed. Aggrieved by the provisional assessment orders, the assessee was constrained to file appeals before the first appellate authority who also after examining the matter from all angles, came to the conclusion that there was no substance in the assessee's appeals, which were accordingly dismissed. Not being satisfied with the orders passed by the aforesaid authorities, the assessee herein preferred further appeals before the Karnataka Appellate Tribunal at Bangalore, but those also met with the fate of dismissal. Hence this revision before us. After having heard the learned counsel for the petitioner/assessee and after perusal of the records, we are of the opinion that no case has been made out for any interference in this revision filed under section 23(1) of the Act. No doubt it is true that the sale had taken place at Bangalore, but other documents revealed that soon after the sale some of the vehicles were taken out of the State and then finally they were registered either at Chennai or at Pondicherry keeping in mind the permanent residential proof of the buyer; otherwise there was no reason why temporary registration certificate was obtained by such buyers by describing their permanent addresses as Chennai or Pondicherry, as the case may be. Apart from this it is also borne out from the records that the said vehicles were financed by various financial institutions whose offices were either at Chennai or Pondicherry. It was not the case of the assessee that such financial institutions did not have any branches at Bangalore. If the buyer of the vehicle was a permanent resident of Bangalore, then he would not have got the financial assistance from the branches which have their office either in Chennai or in Pondicherry. This is indicative of the fact that at the time of the sale the assessee was fully aware that after buying the vehicle, the buyer is going to take the vehicle outside the State of Karnataka. The learned counsel for the petitioner/assessee has placed great reliance on the judgment of the Supreme Court in the case of Commissioner of Sales Tax, U.P., Lucknow v. Suresh Chand Jain reported in [1988] 70 STC 45 to contend that to constitute sale in the course of inter-State trade two conditions have got to be satisfied : (1) sale of goods and (2) transport of those goods from one State to another. We may profitably quote the relevant para of the Supreme Court wherein the case of Bengal Immunity Company Limited v. State of Bihar reported in [1955] 6 STC 446 has also been considered. The said para reads thus : "The principles of inter-State sales were well-settled. In Bengal Immunity Company Limited v. State of Bihar reported in [1955] 6 STC 446 (SC) justice Venkatarama Ayyar had held that sale could be said to be in the course of inter-State trade only if two conditions concur, namely, (1) a sale of goods and (2) a transport of those goods from one State to another. Unless both these conditions were satisfied, there could be no sale in the course of inter-State trade. There must be an evidence that the transportation was occasioned by the contract and as a result goods moved, out of the bargain between the parties, from one State to another." In the light of the aforesaid ratio decidendi of the Supreme Court, learned counsel for the assessee contended that even if condition No. 1 was fulfilled, in any case, condition No. 2 was not fulfilled as there has been interruption from the time the sale was executed by the seller to the buyer till the vehicle was finally taken to the ultimate destination. The word "interruption" is of wider amplitude. It cannot be given a narrow meaning. It cannot be said that the vehicle has to be taken out of the State soon after taking the delivery. There could be some delay for it to be taken to its ultimate destination for variety of reasons, keeping in mind the requirements of the buyer. In the case of Co-operative Sugars (Chittur) Ltd. v. State of Tamil Nadu reported in [1993] 90 STC 1, the following sentence is of great relevance. "... So long as the movement of goods is an incident of the sale/purchase, it amounts to an inter-State sale/purchase. ..." Thus the crucial question that comes up for consideration is whether the movement of the vehicle was an incident of sale/purchase or not. Even if there has been some interruption from the time the sale was executed till vehicle was finally taken to its destination, then it would be covered as inter-State sale. ..." Thus the crucial question that comes up for consideration is whether the movement of the vehicle was an incident of sale/purchase or not. Even if there has been some interruption from the time the sale was executed till vehicle was finally taken to its destination, then it would be covered as inter-State sale. Here, in the case on hand we find that the movement of the vehicle was certainly an incident of the sale/purchase and only thereafter it was taken out of the State of Karnataka. Thus, in our considered opinion, the two conditions which have been made mandatory by the Supreme Court to constitute inter-State sale, having been fulfilled, it would constitute an inter-State sale. It does not lie in the mouth of the petitioner, that even if ultimately the vehicle is taken out of the State of Karnataka, the same would not fall in the category of inter-State sale. Even otherwise the question that has been projected and argued vehemently by the learned counsel for the petitioner is a question of fact, which is not required to be interfered with as all the authorities below after recording its valid and cogent reasons have come to the conclusion that the sale in question would amount to inter-State sale. In view of the aforesaid crystal-clear finding recorded by the Tribunal, there was no case made out for interference, much less, in this revision petition. Hence this revision petition is dismissed in limine. Government advocate is permitted to file his memo of appearance within four weeks.