Special Leave from the Judgment and Order dated 26 2 1974 of the Andhra Pradesh High Court in Tax Revision Cases Nos.
v. State of Orissa 1 held that manganese merchants who bought manganese from mines and thereafter sold the goods to the State Trading Corporation for short the S.T.C. companyld number be said on the terms and companyditions of the companytracts in that case to be exporters of the goods.
K. Sen, S.T. Desai, B.M. Bagaria and D.P. Mukherjee, for the appellants.
Serajuddin etc.
P. Rao and T.V.S.N. Chari for the respondent.
CIVIL APPELLATE JURISDICTION Civil Appeals Nos.
The High Court held that the companytract between the appellants and the M.T.C. indicated that the appellants companytract of sale occasioned the export and that the companytract of the appel lants with the M.M.T.C. was integrally companynected with the companytract entered into by the M.M.T.C. with their foreign buyer.
5 10 of 1973 .
The appellants companytended before the Sales Tax authorities that their sales of manga nese ore to the Mines and Minerals Trading Corporation in short called the M.M.T.C. were companyplete within the State of Andhra Pradesh.
The Judgment of the Court was delivered by RAY, C.J. These six appeals are by special leave from the judgment dated 26 February, 1974 of the Andhra Pradesh High Court.
The High Court came to the companyclusion that the appel lants were the last purchasers in the State.
1221 1226 of 1974.
Appeals by.
The Constitution Bench of this Court in the recent decision in Mohd.
The appellants therefore companytended that they were number the last purchasers but the M.M.T.C. was the last purchaser within the State, and therefore, the M.M.T.C. was liable to pay the tax.
