Report No. 61

Exact question to be decided.- The question for our present purpose therefore naturally arises-which exactly are the sales or purchases of goods taking place in the course of the import of the goods into, or export of the goods out of, the territory of India? And herein lies the rub. My endeavour in this note will be to find out and recommend a correct and proper solution of this question so as to set at rest as far as practicable all doubts and controversies which have been agitating and troubling the minds of all concerned practically since the adoption of the Constitution. And if for this purpose I am to suggest rules, principles, guidelines and criteria which may not be strictly logical and may to some extent even smack of artificiality, I should not hesitate in doing so, for, as has been said, life of the law is not logic but experience.