Concessional purchase turnover used for export-manufactured goods was treated as outside further tax under Section 3(4).

Purchase turnover of raw materials obtained on concessional terms and used to manufacture goods exported to a 100% EOU was stated to fall outside tax under Section 3(4) of the Tamil Nadu General Sales Tax Act, because the issue was already governed by binding precedent holding that an export sale is covered by the first part of Section 3(4) and that the related concessional purchase turnover under Section 3(3) is not assessable again under that provision. On that reasoning, no substantial question of law was found to arise, and the assessee's challenge succeeded on merits.

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Issues: Whether purchase turnovers of raw materials obtained on concessional terms under Section 3(3) of the Tamil Nadu General Sales Tax Act, 1959 and used in the manufacture of goods exported to a 100% EOU could be brought to tax under Section 3(4) of the Act.

Analysis: The dispute was held to be covered by the earlier Division Bench ruling in Tube Investments of India Ltd. v. State of Tamil Nadu, which had already concluded that export sale is a sale within the first part of Section 3(4) and that the corresponding purchase turnover of raw materials availing concessional tax under Section 3(3) could not be assessed to tax under Section 3(4). On that basis, no substantial question of law was found to arise.

Conclusion: The revision was held to be not maintainable on merits and the challenge to the assessment failed, in favour of the assessee.

Ratio Decidendi: Where the issue is already governed by binding precedent, and the transaction concerns export sale of manufactured goods linked to concessional purchases under Section 3(3), no assessable liability under Section 3(4) survives on the same reasoning.

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