State-level import and export regulation can require a separate licence and fee despite prior payment in another State.

A dealer moving molasses into Tamil Nadu for export was still required to obtain an ML-5 licence and pay the prescribed administrative charges under the Tamil Nadu Prohibition Act, 1937 and the Molasses Control and Regulation Rules, 1958. The regulatory scheme treats import into and export out of the State as separate statutory obligations, so payment of export fee in Andhra Pradesh did not remove the liability under Tamil Nadu law. Because the molasses was brought into Tamil Nadu and kept in mixed stock at Chennai Harbour without segregation for export, the State's licence and fee requirements applied, and the challenge to the levy failed.

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Issues: Whether the appellant was liable to obtain an ML-5 licence and pay administrative charges under the Tamil Nadu Molasses Control and Regulation Rules, 1958 for bringing molasses from Andhra Pradesh into Tamil Nadu for export, notwithstanding payment of export fee in Andhra Pradesh.

Analysis: The regulatory scheme under the Tamil Nadu Prohibition Act, 1937 and the Molasses Control and Regulation Rules, 1958 treats import and export with reference to movement into or out of the State, not merely cross-border movement across the customs frontier. A dealer desirous of importing molasses from outside the State or exporting molasses outside the State must obtain an ML-5 licence and pay the prescribed administrative charges. The record showed that the molasses was brought into Tamil Nadu and kept in mixed stock at Chennai Harbour without segregation of the quantity said to be meant for export. Payment of export fee in Andhra Pradesh did not extinguish the separate statutory liability arising under the Tamil Nadu regime.

Conclusion: The appellant was liable to obtain the ML-5 licence and pay administrative charges in Tamil Nadu, and the challenge to the levy failed.

Ratio Decidendi: Where a statutory regime separately regulates import into the State and export out of the State, payment of export-related charges in the originating State does not displace the obligation to obtain the licence and pay the fee prescribed by the destination State for import or export within its own regulatory framework.

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