Binding precedent on export sales under sales tax law defeated the Revenue's levy on out-of-State manufactured goods.

Section 3(4) of the Tamil Nadu General Sales Tax Act was held, in line with binding precedent following Tube Investment of India Ltd., not to support the Revenue's attempt to levy tax on manufactured goods sold outside the State by way of export. The Court treated the questions on the scope of Section 3(4), the situs under Section 2(n) and Explanation 3(a), and the alleged Article 286 infringement as governed by the earlier construction of the provision. The levy was therefore not sustained as contended, the substantial questions of law were answered against the Revenue, and the Tribunal's decision was left undisturbed.

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Issues: Whether tax under Section 3(4) of the Tamil Nadu General Sales Tax Act, 1959 could be levied where the manufactured goods were sold outside the State by way of export, and whether the expression used in that provision could be construed to include such export sales.

Analysis: The challenge turned on the same legal position already considered in earlier decisions following Tube Investment of India Ltd. v. State of Tamil Nadu. The Court treated the controversy as covered by that precedent and held that the statutory scheme did not warrant a different view. The questions framed by the Revenue on the scope of Section 3(4), the relevance of situs under Section 2(n) and Explanation 3(a), and the alleged violation of Article 286 were thus answered in the light of the binding earlier view.

Conclusion: The levy under Section 3(4) was not sustained in the manner contended by the Revenue, and the substantial questions of law were answered against the Revenue.

Final Conclusion: The revision was disposed of by following the earlier precedent, with the Tribunal's decision left undisturbed and no costs awarded.

Ratio Decidendi: Where the dispute is covered by binding precedent on the interpretation of the sales tax provision, the same construction governs subsequent cases and the Revenue's challenge fails.

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