Export-linked trade tax exemption turns on export of manufactured goods, not identity of manufacturer and exporter.

The exemption notification under Section 4-B of the Uttar Pradesh Trade Tax Act, 1948 was construed to apply where specified raw materials were used to manufacture goods that were exported out of India. The language of the notification focused on export of the manufactured goods and did not require the manufacturer and the ultimate exporter to be the same person. On that interpretation, the identity of the exporter was not the decisive condition, and exemption could not be denied solely because the manufacturer and exporter were different persons.

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Issues: Whether the exemption notification under Section 4-B of the Uttar Pradesh Trade Tax Act, 1948 required the manufacturer and the ultimate exporter to be the same person.

Analysis: The notification granted exemption for specified raw materials used in manufacture where the manufactured goods were exported out of India. Its language focused on the export of the manufactured goods and did not stipulate that the manufacturer himself must be the exporter. The decisive condition was export of the goods, not identity between the manufacturer and the exporter.

Conclusion: The requirement that the manufacturer and ultimate exporter must be the same person was rejected, and the assessee could not be denied exemption on that ground alone.

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