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    <title>2007 (1) TMI 521 - ALLAHABAD HIGH COURT</title>
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    <description>Goods moved from the assessee to the Bombay party under a written agency arrangement for procuring export orders and effecting exports. The Bombay party acted as agent, received export proceeds, deducted commission and remitted the balance to the dealers, showing a single export transaction linked to movement of goods to foreign buyers. The absence of a direct contract between the dealers and the overseas purchasers did not alter the export character of the arrangement, because agency principles and the doctrine of undisclosed principal preserve the real nature of the transaction. A Revenue precedent based on a principal-to-principal sale was distinguished. The movement was therefore treated as in the course of export, not an inter-State sale.</description>
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      <description>Goods moved from the assessee to the Bombay party under a written agency arrangement for procuring export orders and effecting exports. The Bombay party acted as agent, received export proceeds, deducted commission and remitted the balance to the dealers, showing a single export transaction linked to movement of goods to foreign buyers. The absence of a direct contract between the dealers and the overseas purchasers did not alter the export character of the arrangement, because agency principles and the doctrine of undisclosed principal preserve the real nature of the transaction. A Revenue precedent based on a principal-to-principal sale was distinguished. The movement was therefore treated as in the course of export, not an inter-State sale.</description>
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