Sivaraj an, J.

T.R.C. No. 145 of 1993 relates to the assessment year 1989-90 in connection with the proceedings under S.29A(4) of the Kerala General Sales Tax Act, 1963. T.R.C. No. 149 of 1993 relates to the same assessment year and arises out of the assessment proceedings for the said year.

2. The assessee is the revision petitioner in both the tax revision cases. The assessee is a distributor for Kirlosker Cumine diesel engine manufactured and marketed by M/s Cumine Diesel Sales and Services (India) Ltd., Pune. The assessee received a purchase order for one engine from M/s. Highland Produce Company Ltd., Pasuparai Estate in Idukki district. The assessee in turn placed an order with M/s. Cumine Diesel Sales and Services (India) Ltd., with specific instruction to despatch the engine directly to costomers site at Pasuparai and to send the document of title to the assessee to enable them to sell the engine by transfer of document of title to the ultimate buyers. In terms of the purchase order, M/s. Cumine Diesel Sales and Service (India) Ltd., Pune, despatched the engine through Kerala Transport Company under cover of delivery note, and a certificate attached thereto showin