Inter-State sales taxation: "in the same manner" covers computation, not State exemptions or single-point levy benefits.

Inter-State sales under the Central Sales Tax Act were held not to take the benefit of State Act exemptions or a single-point levy merely because section 8(2) required tax to be calculated "in the same manner" as an intra-State sale. The Court reasoned that section 6 created the charge on inter-State sales, while section 8(2) governed only the rate and method of computation; it did not incorporate the substantive exemption scheme or point-of-tax rules of the State sales tax law. The State machinery provisions applied only to assessment, collection and enforcement, so the dealer could not exclude inter-State sales on the basis that the goods were taxable only at the first sale under the State Act.

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Issues: Whether inter-State sales taxable under the Central Sales Tax Act, 1956 could claim exemption or the benefit of a single-point levy available under the Mysore Sales Tax Act, 1957 when tax was to be calculated at the same rates and in the same manner as if the sale had taken place inside the appropriate State.

Analysis: Section 6 created the charge on all inter-State sales, while section 8(2) dealt only with the rate and manner of calculation of tax. The expression "in the same manner" in section 8(2), read with section 9(1) and 9(2), did not incorporate the whole substantive State sales tax law so as to import exemptions or the point of levy fixed by the State Act. The machinery provisions of the State law were attracted only for assessment, collection and enforcement, and the Central Act did not yield to the State law in a way that would cut down the charging provision or convert inter-State sales into intra-State sales for exemption purposes.

Conclusion: The dealer was not entitled to exclude inter-State sales from tax on the ground that, under the State Act, the goods were taxable only at the first or earliest sale. The appeal failed.

Ratio Decidendi: The words "in the same manner" in the Central Sales Tax Act relate to the method of calculation and the assessment machinery, not to the substantive exemptions or point-of-tax rules under the State sales tax law.

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