Judgment :- 1. The only contention urged before me is that the petitioner should not have been assessed to sales tax in respect of certain sales in which the buyers were outside the State and delivery was effected to the agents of those buyers within the State either at Trichur or at Mattancherry. According to the petitioner those sales took place "in the course of inter-State trade or commerce" and are hence exempt from taxation under Art.286(2) of the Constitution. 2. There is nothing in the papers produced before me to indicate that the sales concerned were "in the course of inter-State trade or commerce". As pointed out by Venkatarama Ayyar, J., in the Bengal Immunity case (1955) VI STC 446 (583). "A sale could be said to be in the course of inter-State trade only if two conditions concur: (1) A sale of goods, and (2) a transport of those goods from one State to another under the contract of sale. Unless both these conditions are satisfied, there can be no sale in the course of inter-State trade. 3. The two conditions do not concur in this case and in the light of the observations in the Bengal Immunity Case and the judgment of this court in O.P. No. 191 of 1955, I see no reason to order "notice" on this petition. 4. In (1947) 76 CLR 414 Dixon, J., said: "We should consider the commercial significance of transactions and whether they form an integral part of a continuous flow or course of trade, which apart from the theoretical legal possibilities, must commercially involve transfer from one State to another." and the passage quoted with approval by Das. J., in AIR 1953 Supreme Court 333 (349). I am quite prepared to look at the transactions purely from the point of view of their commercial significance. Even then it is impossible to say that they form "in integral part of a continuous flow or course" of inter-State trade or commerce. 5. The petition is hereby rejected. Rejected.