1981 (11) TMI 173

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....this revision, the State contends that when an exporter of pepper purchases pepper and after the process of garbling, exports such pepper, it is not a purchase in the course of such export despite section 5(3) of the Central Sales Tax Act for the reason that the goods exported, according to the State, is not the same as goods purchased by the exporter. Section 5(3) of the Act reads: "(3) Notwit....

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....fferent goods. We cannot agree with the counsel that merely because pepper purchased by an exporter is subject to process, the process being one of cleaning and making it presentable for the export market, it will cease to be the same as it was. Pepper does not undergo a process which changes its character so as to render it a different commodity in commerce. What is purchased by the exporter was ....