Export-linked purchase exemption failed where no prior foreign contract or evidence established the required export nexus for sales tax relief.

Local purchase of cashew kernel was not treated as a purchase in the course of export because the assessee failed to prove an export nexus. No evidence showed a prior contract between the selling dealer and the foreign purchaser, and the claim was unsupported by material on record. Applying the earlier view rejecting a similar contention, the purchases were held exigible to sales tax and the exemption claim failed.

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Issues: Whether the local purchase of cashew kernel was liable to sales tax or was exempt as a purchase in the course of export.

Analysis: The assessee claimed that the purchases were in the course of export and therefore exempt. The finding of fact was that no evidence established the export nexus and there was no prior contract between the selling dealer and the foreign purchaser. The claim was also unsupported by material on record, and the earlier judicial view rejecting a similar contention was applied.

Conclusion: The claim of exemption failed and the purchases were held exigible to sales tax.

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