Export-linked purchase tax exemption requires the purchase itself to occasion export, not merely eventual export of goods.

Purchases of hemp jute were not exempt from purchase tax merely because the goods were later exported. The exemption under section 50(1)(iii) of the Madhya Pradesh General Sales Tax Act, read with section 5(1) of the Central Sales Tax Act, applies only where the purchase itself is in the course of export, meaning it occasions the export or is effected by transfer of title documents after the goods cross the customs frontiers of India. As the purchases from local agriculturists and unregistered dealers were distinct from the later export sale and no direct link to the export was established, the purchases remained liable to purchase tax.

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Issues: Whether purchases of hemp jute by the assessee were exempt from purchase tax as purchases made in the course of export of goods out of the territories of India under section 50(1)(iii) of the Madhya Pradesh General Sales Tax Act, 1958, read with section 5(1) of the Central Sales Tax Act, 1956.

Analysis: The exemption under section 50(1)(iii) applied only where the purchase itself took place in the course of export. Under section 5(1) of the Central Sales Tax Act, a purchase is in the course of export only if it occasions the export or is effected by transfer of documents of title after the goods cross the customs frontiers of India. On the facts found, the assessee's purchases from local agriculturists and unregistered dealers were separate from the later sale to an buyer, and no necessary link was established between the purchases and the export. The purchases at most were made for the purposes of export, but they did not occasion the export.

Conclusion: The purchases were not exempt under section 50(1)(iii) of the Madhya Pradesh General Sales Tax Act, 1958, and were liable to purchase tax under section 7 of that Act.

Ratio Decidendi: A purchase is not in the course of export merely because the goods are eventually exported; the purchase itself must occasion the export or satisfy the statutory conditions linking it directly to the export transaction.

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