Ben Gorm Nilgiri Plantations Company, ... vs Sales Tax Officer, Special Circle, ... on 10 April, 1964
Referring to the case of Wadeyar (supra) Shah J. speaking
for the majority in the case of Ben Gorm Nilgiri Plantations
Co. (supra) observed
"This was undoubtedly a case of two sales
resulting in export, and the first sale was
held immune from State taxation: but that was
so because the property in the goods had
passed to the Indian purchaser when the goods
were in the export stream. The first sale
itself was so inextricably connected with the
export that it was regarded as a sale in the
course of export."