( 1 ) THESE five T. R. Cs are disposed of by a common judgment as the question of law involved is one and the same.

( 2 ) THE petitioners in all these cases is M/s. M. M. T. C. (India) Ltd. , Visakhapatnam which is a Government of India undertaking. For the sake of convenience, we are referring to the facts in T. R. C. No. 43 of 1991 as the facts are exactly similar in the other connected cases also T. R. C. No. 43of 1991 the assessment year is 1984-85. T. R. C. No. 92 of 1995 the assessment year is 1983-84. T. R-C. No. 112 of 1995 the assessment year is 1982-83. T. R,c. No. 40 of 1995 the assessment year 1987-88. T. R. C. No. 12 of 1995 the assessment year is 1983-84.

( 3 ) FOR the assessment year 1984-85 the assessee claimed exemption on a turnover of Rs. 16,09, 11,777. 30 and Rs. 17,29,74,326. 42 as the sales in the course of import of sulphur and rock phosphate falls under the 2nd limb of Section 5 (2) of the CST Act (herein after referred to as the Act ). The plea of the petitioner is that it has imported goods from foreign parties and as it has transferred the bills of lading in favour of the local buyers before the customs clearance of goods was effected, t