Report No. 30

64. All transactions under Article 286(1)(b) covered by the Supreme Court decisions.- From this enumeration, it would be seen that the Supreme Court has by its interpretation of Article 286(1)(b) analysed and covered all the transactions of sale or purchase which take place in the course of the import of the goods into, or export of the goods out of, the territory of India.

In fact, by not adopting a mechanical test (see para. 13 of the I Travancore case, AIR), the Supreme Court put a liberal construction upon Article 286(1)(b) by including in the category of transactions taking place in the course of export or import, a sale which occasions export as taking place in the course of export and a purchase which occasions import as taking place in the course of import, though such sale or purchase does not literally take place in the course of export or import.