Mr. Purshottam Tricumdas, appearing for the petitioner, raised before us the following contentions: (1) Under article 286(1)(b) of the Constitution, as it stood before the Constitution (Sixth Amendment) Act, 1956, the sales in question were not liable to sales tax inasmuch as they took place in the course of import of the 857 goods into the territory of India; (2) the said sales were exempted from sales tax by the Bombay State under the explanation to article 286(1) of the Constitution, as the goods were delivered for the purpose of consumption in States other than Bombay; (3) the sales were effected outside the State of Bombay i.e., New Delhi, and therefore they were also exempted under article 286(1)(a) of the Constitution; and (4) the first respondent could have only interfered with the earlier order of assessment under section 15 of the Act within three years from the end of the assessment year 1954 55, i.e., March 31, 1955, and that the said period having elapsed, he had no power to interfere in revision under section 31 of the Act.