Export purchase exemption denied where local supplier was not the exporter and the last-purchase levy applied.

Purchases of hides and skins made locally for supply to an exporter did not qualify as purchases in the course of export under section 5(3) of the Central Sales Tax Act, 1956. That exemption applies only to the last sale or purchase preceding export, where the transaction is integrally connected with the export movement. Because the assessee was only a supplier to the exporter and not the exporter itself, the statutory test was not met. The goods were therefore liable to the State levy at the point of last purchase within the State, and the exemption claim failed.

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Issues: Whether the purchases of hides and skins made by the assessee for supply to an exporter could be treated as purchases in the course of export so as to attract the exemption under section 5(3) of the Central Sales Tax Act, 1956.

Analysis: The exemption under section 5(3) applies where the transaction is the last sale or purchase preceding the export and is integrally connected with the export movement. The assessee here was not the exporter; he was only a supplier to an exporter. The factual material showed that the goods were purchased locally and supplied to the exporter at his request, while the levy under the State law attached at the point of last purchase within the State. On those facts, the transaction did not answer the statutory description of a sale or purchase in the course of export, and the claim to exemption under section 5(3) could not succeed.

Conclusion: The purchases were not in the course of export and were not exempt under section 5(3) of the Central Sales Tax Act, 1956; the levy at the point of last purchase under the State Act was upheld.

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