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1996 (10) TMI 394 - SC - VAT and Sales TaxLiability for sales tax - Held that:- Appeal allowed. There is no endorsement on the bill of lading in favour of STC that would suggest transference to it of title in the tea. There is, therefore, nothing in the contract between the appellants and STC or in the manner of its execution that establishes that there was a transfer of the property in the tea by the appellants to STC before it was transferred to the Iranian buyer. Hence, the purchase of the tea by the appellants at the auctions in fulfilment of the export obligation to the Iranian buyer was the penultimate sale in the course of export and covered by the terms of section 5(3). It was, accordingly, exempt from the payment of sales tax.
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