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Issues: Whether the sale of gunny bags to another dealer for use as containers in the export of goods qualified as a deemed export sale under section 5(3) of the Central Sales Tax Act, 1956.
Analysis: Section 5(3) applies where the last sale or purchase preceding the export is made after, and for the purpose of complying with, an agreement or order relating to such export. On the facts found by the Tribunal, the sale of the bags was connected with the export transaction and satisfied both statutory conditions.
Conclusion: The sale was covered by section 5(3) and was treated as a sale in the course of export.