Processed prawns remained the same goods for export exemption under the Central Sales Tax Act.

Processed prawns purchased and exported after cleaning, peeling and sorting were treated as the same commodity for exemption under section 5(3) of the Central Sales Tax Act. The Supreme Court ruling that processing did not change the identity of the goods directly governed the issue, so the Tribunal's view in favour of the assessee was upheld and the exemption benefit was allowed.

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Issues: Whether prawns purchased and exported after cleaning, peeling and sorting remained the same goods for the purpose of exemption under section 5(3) of the Central Sales Tax Act.

Analysis: The question was concluded by the Supreme Court decision holding that prawns purchased and exported after processing remained one and the same commodity notwithstanding the processes employed. That ruling directly governed the facts, and the Tribunal's view in favour of the assessee was found to be correct.

Conclusion: The processed prawns were held to be the same goods as the purchased prawns, and the assessee was entitled to the benefit of section 5(3) of the Central Sales Tax Act.

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