C.N. RAMACHANDRAN NAIR,J.

1. The revision petitioner, engaged in the sale of Yamaha two wheelers at Thrissur, is a registered dealer under the Kerala value Added Tax Act, 2003 (for short ‘the KVAT Act’) During 2005 –2006 and 2006-2007, the petitioner conducted exchange melas wherein two wheeler owners were provided with facility to exchange their old vehicles with new ones. The petitioner arranged a broker for purchaser of old vehicles form the customers at the value fixed by the broker. If the value fixed by the broker is accepted by the customer, then he can purchase the new vehicle from the petitioner by remitting the balance sale price. The petitioner sold new vehicles at the original cost to the customer, but by collecting only the price of the new vehicle refused by the value of the customer’s old vehicle fixed buy the broker. The old vehicle is delivered by the customer then and there and the broker takes over possession of the same with the documents. According to the petitioner, the broker later sells the old vehicles delivered by the customers and remit the value earlier fixed to the petitioner with which the entire price of the new vehicles sold to the custome