Sales tax exemption applies transaction by transaction, and unsupported blanket immunity claims can be rejected

Constitutional and statutory exemptions from sales tax attach to specific transactions, not to a dealer's personal residence or status. Sales or purchases shown to have taken place within the State remain taxable unless the assessee proves that each transaction falls within the course of import or export. Where account books or other supporting materials are not produced to separate exempt from taxable transactions, the assessing authority may adopt best judgment and complete the assessment accordingly. A blanket claim of immunity for all transactions was rejected, and the assessments were sustained.

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Issues: Whether the petitioners were entitled to claim absolute immunity from sales tax on all transactions carried on within Andhra Pradesh on the ground that they were residents of Yanam and that the transactions were in the course of import or export.

Analysis: The protection under the Constitution and the Act attaches to transactions of a particular nature and not to persons as such. Transactions admittedly or proved to have taken place within the State remain taxable unless the assessee establishes that each transaction falls within the constitutional exemption as a sale or purchase in the course of import or export. Where the assessee does not produce account books or other materials to enable the assessing authority to distinguish exempt transactions from taxable ones, the authority is entitled to proceed on best judgment and make the assessment accordingly. A general claim that all transactions are immune from tax cannot be accepted.

Conclusion: The claim of blanket immunity was rejected, and the assessments made by the taxing authority were upheld.

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