Export sales and concessional purchases under Tamil Nadu sales tax law were outside additional tax liability on manufacturing inputs.

Additional tax under Section 3(4) of the Tamil Nadu General Sales Tax Act, 1959 was not leviable on purchase turnovers of raw materials used in goods manufactured for export. The Court accepted the earlier Division Bench view that export sale is a "sale" within Section 2(n) read with Explanation 3(a), and that the phrase "any other manner" in Section 3(4), read by ejusdem generis, does not extend to export sales. As later precedent had followed the same interpretation, the Tribunal's reliance on binding authority was upheld and the assessee's position was accepted.

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Issues: Whether additional tax under Section 3(4) of the Tamil Nadu General Sales Tax Act, 1959 was leviable on purchase turnovers of raw materials used in goods manufactured and sold in the course of export.

Analysis: The dispute turned on the interpretation of Section 3(4) of the Tamil Nadu General Sales Tax Act, 1959 in the context of concessional purchases under Section 3(3). The Court accepted the earlier Division Bench view that export sale is a "sale" within Section 2(n) read with Explanation 3(a), and that the expression "any other manner" in Section 3(4), applied by ejusdem generis, does not cover export sales. It further noted that the same view had been followed in later precedent, and therefore the Tribunal had rightly applied binding authority.

Conclusion: Additional tax under Section 3(4) was not attracted to the purchase turnovers corresponding to export of manufactured goods, and the issue was answered in favour of the assessee.

Ratio Decidendi: Export sales are covered by the definition of "sale" under the Tamil Nadu General Sales Tax Act, 1959, and Section 3(4) does not extend additional tax liability to such export transactions on concessional purchases of inputs used in manufacture.

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