GOVINDAN NAIR, C.J.

These revisions are taken by the revenue against the order of the Tribunal holding that the turnover of Rs. 2, 07, 878.77 representing the alleged sales effected by the Madras Motor Parts Dealers' Association to its members are not taxable and they are really and in law sales in the course of import. The short question is whether the said turnover for the year 1971-72 is taxable under the Tamil Nadu General Sales Tax Act. While the revenue contends that the turnover represented local sales coming under that head, on behalf of the assessee it was contended that those sales were in the course of import and that if that contention is not accepted, it is clear from the facts that there were really no sales by the assessee to its members. We shall consider these aspects. Before doing so, we have to refer to certain facts and certain agreements.

The Madras Motor Parts Dealers' Association is an association of its constituents who are all dealers in motor parts. The members wanted to import certain parts which were in demand and which were importable pursuant to agreements entered into between India and other countries on making payments in rupees. They, ther