STATE OF KARNATAKA vs AZAD COACH BUILDERS PVT. LTD.

The Supreme Court held that under Section 5(3) of the Central Sales Tax Act, 1956, the assessee, Azad Coach Builders Pvt. Ltd., is entitled to the benefit of exemption as the export involved the complete bus, despite the department's claim that the sale was only for the bus-body. The Court clarified that the identity of the bus remained unchanged after the body was constructed, thus constituting a penultimate sale. The judgment distinguished the nature of the transaction from previous rulings, affirming the assessee's entitlement to the exemption under the Act.