https://www.taxtmi.com/caselaws?id=38186 In routed export transactions, the Corporation was treated as a facilitative intermediary rather than the real purchaser because the exporters sourced the goods, negotiated with foreign buyers, bore the commercial risk, financed the transactions and received sale proceeds through their bankers while paying only a commission. The shipping and GR-1 documents were not conclusive where the surrounding conduct showed no substantive sale to the Corporation. On that basis, entitlement to the export incentive under section 280ZC depended on the real exporter in substance, not the ostensible party in the paperwork. The exporters were therefore entitled to the tax credit certificate, and the matter was remitted for reconsideration accordingly. en-us Thu, 25 May 1978 00:00:00 +0530 Sat, 03 Apr 2010 16:12:20 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=38186 In routed export transactions, the Corporation was treated as a facilitative intermediary rather than the real purchaser because the exporters sourced the goods, negotiated with foreign buyers, bore the commercial risk, financed the transactions and received sale proceeds through their bankers while paying only a commission. The shipping and GR-1 documents were not conclusive where the surrounding conduct showed no substantive sale to the Corporation. On that basis, entitlement to the export incentive under section 280ZC depended on the real exporter in substance, not the ostensible party in the paperwork. The exporters were therefore entitled to the tax credit certificate, and the matter was remitted for reconsideration accordingly. Case-Laws Income Tax Thu, 25 May 1978 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=38186