Export-linked sale exemption under sales tax law depends on compliance with export orders, not manufacture of every component.

Section 5(3) of the Central Sales Tax Act treats the last sale or purchase preceding an export sale as part of the export where it is made after, and for the purpose of, complying with the export agreement or order. The provision does not require the dealer to manufacture every component of the exported goods, and no separate distinction was accepted between football or volleyball covers and the bladders used with them when the sale was shown to comply with export orders. On that basis, the dealer was held not entitled to exemption on the ground urged, and the Tribunal's allowance of the exemption was upheld.

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Issues: Whether the dealer was entitled to exemption under section 5(3) of the Central Sales Tax Act where it manufactured football and volleyball covers but not the bladders used with them.

Analysis: Section 5(3) deems the last sale or purchase preceding the export sale to be in the course of export if it is made after and for the purpose of complying with the agreement or order for such export. The provision does not require the dealer to manufacture every component of the exported goods, and no distinction can be drawn in the manner suggested between covers and bladders when the sale is shown to have been made in compliance with export orders.

Conclusion: The dealer was not entitled to claim exemption on the ground urged, and the Tribunal's view allowing the exemption was upheld.

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