R. JAYASIMHA BABU, J.

For the assessment years 1982-83 and 1983-84, the petitioner has been assessed to Central sales tax on the cement transported by it from the Port of Tuticorin to the premises of the petitioner's customers in the State of Kerala. The petitioner being aggrieved by the order of the Tribunal, which has upheld that levy, has come up in revisions.

2. Petitioner is an undertaking owned by the State of Kerala and as its name certifies it as a Corporation established for the purpose of promoting small industries development and employment therein in the State of Kerala. It admittedly did not have a regular place of business in the State of Tamil Nadu. The activities of the petitioner which led to the present proceedings arose out of the import of cement by the petitioner between 1982 and December, 1983. According to the respondent, the petitioner established a place of business at Ramaiah lodge in Tuticorin where its Liaison Officer was staying and had used the port as a place of storage of cement and had effected inter-State sales therefrom.

3. It is not in dispute that the cement transported from the Port of Tuticorin to the premises of the customers of the