State Of Karnataka vs Azad Coach Builders Pvt. Ltd. & Anr

The Supreme Court examined the eligibility of an assessee for exemption under Section 5(3) of the Central Sales Tax Act, 1956, determining that the penultimate sale must be inextricably connected to the export of goods. The Court reaffirmed the interpretation from previous judgments, including Md. Serajuddin and Sterling Foods, emphasizing that the goods purchased must be the same as those exported. The Court held that the exemption applies only when the goods retain their identity through the export process, thereby clarifying the application of the 'same goods' theory in tax exemptions.