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    <title>2019 (8) TMI 1097 - ALLAHABAD HIGH COURT</title>
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    <description>Goods supplied under a commercial arrangement were treated as intra-State sales because the assessee did not prove, with contract documents and books of account, that the identified goods moved pursuant to a pre-existing contract of sale. A godown in Uttar Pradesh and transport descriptions alone were held insufficient to split the transaction into separate sales. The alternative plea that the supply fell under a works-contract exclusion was also rejected because that factual and legal basis had not been established before the lower authorities and could not be raised for the first time in revision. The assessment and appellate findings were left undisturbed.</description>
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