MURARILAL SARAWAGI ETC. vs THE STATE OF ANDHRA PRADESH

The Supreme Court held that under Item 1 of the Second Schedule to the Andhra Pradesh General Sales Tax Act, 1957, the last purchaser liable for sales tax on manganese ore is the dealer who sells within the State. The Court found that the appellants' contracts with the MMTC were not integrated with the export contracts to foreign buyers, thus the appellants were the last purchasers liable for tax, not the MMTC. The Court clarified that only one sale can be deemed to cause export, emphasizing that the sale must directly result in the movement of goods from exporter to importer.