High Court p11t on the notification dated January 28, 1956, is not correct. We think that this contention is right and must be accepted, The notificatiJn clearly lays down three conditions for the grant of exemption: one of the conditions is that the sale must be of such shoes, chappals, country .shoes and footwear as are hand-made and not manufactured on power machine; the second condition is· that the sale price must not exceed Rs. 12/8/-; and the third condition is that the sale must be by the manufacturer or any member of his family. The notification when it uses the expression ''in case of sale" must refer to the sale which is being exempted from tax in thf' State; in other words, it has reference to tbe taxable event in the State as per ::>oh. 3 of the notification dated October 24, 1953. That notification makes it clear that the tax is a single point tax, and the taxable event is the sale by the importer or manufacturer in the State. Therefore, the expression "in case of sale" in the exemption notification can have no reference to a sale outside the State. The High Court was in error when it said that, it made no difference whether tbe sale was by the manufacturer within the State directly to the purchaser or whether the sale was by the manufacturer outside the State to the importer who · then sold the shoes to the purchaser in the i::ltate. When a manufacturer sells shoes outside the State to an importer and the importer again sells shoes in the State, there are really two sales, one outside the State and one inside it. The sales outside the State are not taxable under the Act and the notification of January 28, 1956, has no reference to such sales. When the notification uses the expression "in case of sale by the manufacturer or a member of his family';, it has reference to such sales as would come but for the exemption within item 32 of Sch. 3 of the notification dated October 24, 1953. If the interpretation put· by the High
