Report No. 30

63. Which transactions according to Supreme Court, are in the course of export or import.- From this and the two Travancore cases it is clear which particular transactions would be in the course of export and which, in the course of import. For convenience, I may enumerate them here:-

(1) A sale which occasions export would be in the course of export.

(2) A purchase which occasions import would be in the course of import.

(3) A sale or purchase which is effected by transfer of shipping documents while the goods are on the high seas would be in the course of export. (Such transactions would be very rare but are not inconceivable. See para. 13 of the I Travancore case and para. 15 and 49 of the II Travancore case, AIR).

(4) A sale or purchase, effected by transfer of shipping documents while the goods are on the high seas, would be in the course of import. (See para. 13 of the I Travancore case and para. 15 and 49 of the II Travancore case, AIR; and also the facts of this case i.e. J.V. Gokal's case).