Export sales under concessional raw material purchases were held covered by binding precedent, defeating the purchase turnover tax challenge.

Export sales of manufactured goods were treated as falling within the scope of Section 3(4) of the Tamil Nadu General Sales Tax Act for the purpose of taxing the purchase turnover of raw materials obtained at concessional rate on Form XVII declarations. The court noted that the issue was already covered by Tube Investment of India Ltd., and the departmental representative accepted that the earlier decision governed these revisions. The Revenue's challenge therefore failed, and the Tribunal's view in favour of the assessee was maintained.

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Issues: Whether export sales of manufactured goods fall within the expression used in Section 3(4) of the Tamil Nadu General Sales Tax Act, 1959 so as to attract tax on the purchase turnover of raw materials obtained at concessional rate.

Analysis: The Tribunal had allowed the assessee's appeal by treating export as a sale for the purposes of Section 3(4). In these revisions, the State relied on the same statutory framework and the challenge was confined to the tax liability arising from export of goods manufactured from raw materials purchased on Form XVII declarations. The Court noted that the very issue had already been considered in Tube Investment of India Ltd. and that the departmental representative accepted that the earlier decision governed the present cases.

Conclusion: Export sale was treated as covered by the earlier binding decision, and the revisions failed. The question of law was answered against the Revenue and in favour of the assessee's stand before the Tribunal was maintained.

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