1. These two original petitions concern the question of levy of tax under S.3 of the Kerala Motor Vehicles Taxation Act. 1976. for short the M.V.T. Act. The facts of the two cases are almost identical and so these two cases can be disposed of by a common judgment.

2. We shall now advert to the facts necessary for the disposal of these cases. The petitioners in both these original petitions are doing the business of loading & unloading the containers/vessels reaching the wharf area in Cochin Port. The petitioner in O.P. No 2365 of 1987 is acting as the agents of Sealand Services incorporated in the United States of America. For facilitating loading and unloading the containers/vessels. the petitioner is using chassis (trailer). according to the petitioner. specially designed and adapted for leading and unloading the containers/vessels reaching the Cochin Port. The principal of the petitioner in O.P. No. 2365 of 1987 has imported from Roferdam 105 chassis (trailers) for the above said purpose. The petitioner in O.P No. 9652 of 1987 got permission from the Central Government and Port authorities to import 55 chassis (trailers) from their principal. United States Lines. whic