https://www.taxtmi.com/caselaws?id=161083 The statutory fiction treating paddy and rice as a single commodity was confined to the limited purpose of export-linked exemption under section 5(3) of the Central Sales Tax Act. That exemption applied to the export sale and the penultimate sale preceding export, but not to the miller's earlier purchase of paddy from the market or a commission agent; accordingly, such purchase remained liable to purchase tax. The challenge to assessment orders was also held to be better pursued through the statutory appellate remedy where factual verification of returns and transactions was required. Administrative instructions merely drawing attention to binding High Court precedent were not unlawful interference with quasi-judicial discretion. en-us Tue, 28 Aug 2001 00:00:00 +0530 Tue, 31 Dec 2013 15:53:12 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=161083 The statutory fiction treating paddy and rice as a single commodity was confined to the limited purpose of export-linked exemption under section 5(3) of the Central Sales Tax Act. That exemption applied to the export sale and the penultimate sale preceding export, but not to the miller's earlier purchase of paddy from the market or a commission agent; accordingly, such purchase remained liable to purchase tax. The challenge to assessment orders was also held to be better pursued through the statutory appellate remedy where factual verification of returns and transactions was required. Administrative instructions merely drawing attention to binding High Court precedent were not unlawful interference with quasi-judicial discretion. Case-Laws VAT and Sales Tax Tue, 28 Aug 2001 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=161083