https://www.taxtmi.com/caselaws?id=101946 Section 5(3) of the Central Sales Tax Act was treated as a valid rule of legal classification for penultimate sales in the course of export, not as an unconstitutional fiction. Its reference to "the agreement or order for or in relation to such export" was construed in commercial context as requiring an agreement or order with a foreign buyer, so a mere local covenant to export was insufficient. In Coffee Board export auctions, property in the coffee passed only on payment of the full price, weighment and setting apart for delivery; the export-linked agreement or order had to exist before that stage for section 5(3) to apply. en-us Tue, 15 Apr 1980 00:00:00 +0530 Tue, 08 Jul 2025 15:18:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=101946 Section 5(3) of the Central Sales Tax Act was treated as a valid rule of legal classification for penultimate sales in the course of export, not as an unconstitutional fiction. Its reference to "the agreement or order for or in relation to such export" was construed in commercial context as requiring an agreement or order with a foreign buyer, so a mere local covenant to export was insufficient. In Coffee Board export auctions, property in the coffee passed only on payment of the full price, weighment and setting apart for delivery; the export-linked agreement or order had to exist before that stage for section 5(3) to apply. Case-Laws VAT / Sales Tax Tue, 15 Apr 1980 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=101946