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    <description>Transfer of REP licences or Exim scrips to designated State Bank of India branches for onward forwarding to the licensing authorities on receipt of premium did not constitute a sale of goods. Although such licences are goods when assigned to a third party for consideration, a different position applies when they are returned to the grantor or sovereign authority for cancellation or extinction, because they then cease to be marketable commodities and lose value for market purposes. The bank acted only as an agent in the cancellation process, and the object was extinction of the rights embodied in the licences rather than purchase of goods; accordingly, the premium was not liable to sales tax.</description>
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