(Dr. Chandrachud, J.)

Leave to amend in terms of the draft tendered and taken on record. The amendment may be carried out during the course of the week. Verification dispensed with.

2. The First Petitioner is a Company which is engaged in the express package distribution business, more popularly described as a courier service. The Petitioners accept consignments on behalf of consignors for delivery at various destinations within and outside the country. Section 194A of the Mumbai Municipal Corporation Act, 1888 provides for an exemption from octroi of articles which are meant for immediate exportation. Octroi is imposed on goods which are imported into the limits of the Municipal Corporation for consumption, use or sale.

3. Section 194A is in the following terms:

“194A. Exemption of articles imported for immediate exportation.- Subject to such rules, not inconsistent with this Act, as the Commissioner, with the approval of the Standing Committee, shall from time to time frame in this behalf, any article imported into Brihan Mumbai for the purpose of immediate exportation shall be exempted from the levy of octroi, if such article is conveyed direct from the place of imp