V. RAMASWAMI, J.

The respondents-assessees are exporters of iron manganese ore. For the asst. yr. 1960-61 they returned a turnover of Rs. 17, 13, 142.26 and claimed exemption in respect of the entirety on the ground that the turnover related to export sales. Rejecting the contention, the AO held that the assessee are not the exporters and that the sales are local sales liable to the taxed under the Tamil Nadu General ST Act. This view was confirmed by the AAC; but, on further appeal, the Tribunal held that the entire turnover was exempt from sales-tax on the ground that they are export sales. The facts are not quite clear; but, it is seen from the order of the AAC that a major portion of the turnover related to exports by the State Trading corporation of India. The contracts were entered into by the State Trading Corporation of India with for the buyers. The export licences are also only with the State Trading Corporation of India. Since the exports of manganese ore was channelised some time from the middle of 1960 through the State Trading Corporation of India the assessees could not themselves export directly. The bill of lading was also taken in the name of the State