High-seas sale treatment requires proof that title passed before...

High-seas sale treatment requires proof that title passed before goods crossed the customs frontier; invoices raised after entry into India, a Tamil Nadu factory address, and customs duty paid by the dealer did not establish such sales. The imported-car transactions were therefore taxable under the TNGST Act. The G.O.Ms.No.381 exemption required goods purchased against declaration to be used for the stated manufacturing purpose. Failure to correlate purchases with exports or prove declared use triggered tax liability, and compounding fees could not replace that consequence. The Tribunal could correct the appellate misapplication of the exemption despite no departmental appeal.