TMI Blog1981 (11) TMI 173X X X X Extracts X X X X X X X X Extracts X X X X ..... cess of garbling, exports such pepper, it is not a purchase in the course of such export despite section 5(3) of the Central Sales Tax Act for the reason that the goods exported, according to the State, is not the same as goods purchased by the exporter. Section 5(3) of the Act reads: "(3) Notwithstanding anything contained in sub-section (1), the last sale or purchase of any goods preceding the ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... subject to process, the process being one of cleaning and making it presentable for the export market, it will cease to be the same as it was. Pepper does not undergo a process which changes its character so as to render it a different commodity in commerce. What is purchased by the exporter was pepper and what is sold by him is pepper. Garbling, as rightly presented by the Appellate Tribunal, is ..... X X X X Extracts X X X X X X X X Extracts X X X X
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