VEERASWAMI, J.

The assessee admittedly acted as a local agent of his non-resident principal. He also carried on a business of his own. During the accounting year, the assessee transferred the goods of his non-resident principal to his own business and on this transaction he admittedly collected commission from his non-resident principal. The question is whether the transaction involved a sale chargeable to tax. The revenue authorities as well as the Tribunal have uniformly held and in our opinion quite rightly, that the transaction involved a sale and will be liable to local tax.

It is argued that the same person cannot sell goods to himself. That is true enough. But here, the same person held two different capacities, one as an agent of a non-resident principal and the other as proprietor of his own business, two different entities altogether. When he transferred the goods to himself, he not only acted in that transaction as the agent of his non-resident principal, but also as a purchaser. There is nothing wrong in this dual capacity coming into play in this transaction which, as we think, is clearly within the definition of a "sale" in the Act. There is no reason to int