Report No. 30

39. Burmah Shell case.-In Burmah Shell Oil Standard Co. v. Commercial Tax Officer, [AIR 1961 SC 311: (1061) 1 SCR 902], the Supreme Court observed, that the test of export is that the goods must have a foreign destination where they can be said to be imported. The crucial fact is the sending of the goods to a foreign destination where they would be received as imports. The country to which the goods are sent is said to import them and the words "export" and "import" are complementary. The two notions of export and import thus go in pairs.