https://www.taxtmi.com/caselaws?id=153201 The deeming Explanation to Entry 84 of the First Schedule to the Tamil Nadu General Sales Tax Act applies only where timber or bamboo is purchased by forest contractors in auctions of forest coupes conducted by the forest department. That statutory fiction is limited and cannot be extended beyond its express terms. Timber purchased from Government Timber Depots is not the same as timber bought in a forest coupe auction, so the conditions for treating the resale as the first sale were not satisfied. On that basis, the Explanation did not apply to the assessee's turnover and the assessment treating the resale as a deemed first sale was unsustainable. en-us Thu, 20 Aug 1981 00:00:00 +0530 Fri, 19 Jul 2013 13:10:02 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=153201 The deeming Explanation to Entry 84 of the First Schedule to the Tamil Nadu General Sales Tax Act applies only where timber or bamboo is purchased by forest contractors in auctions of forest coupes conducted by the forest department. That statutory fiction is limited and cannot be extended beyond its express terms. Timber purchased from Government Timber Depots is not the same as timber bought in a forest coupe auction, so the conditions for treating the resale as the first sale were not satisfied. On that basis, the Explanation did not apply to the assessee's turnover and the assessment treating the resale as a deemed first sale was unsustainable. Case-Laws VAT and Sales Tax Thu, 20 Aug 1981 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=153201