( 1 ) THESE revision petitions under section 23 of the Karnataka Sales Tax Act, 1957 (KST Act), are by the Cashew Corporation of India Limited (Corporation) and are directed against the common order dated 31st March, 1981, of the Karnataka Appellate Tribunal, Bangalore (Tribunal), in s. T. Appeals Nos. 185 to 190 of 1978.

( 2 ) THE Corporation is a subsidiary of the State Trading Corporation owned by the Government of india. The Corporation came to be constituted in August, 1970, and has its registered office at cochin in Kerala State. The Corporation is a registered dealer under the Sales Tax Act of that state but is not a registered dealer under the KST Act of Karnataka State. The Corporation imports cashew from East African countries under licences issued by the Controller of Imports and Exports and allots the imported cashew to actual users for being proceeded and for export of certain percentage of the raw cashew so allotted. One of the conditions of the import licence granted to the Corporation is that it should remain as the owner of the cashew imported under the licence up to the time of clearance through customs. Prior to the coming into existence of the cor