https://www.taxtmi.com/caselaws?id=49451 Inter-branch despatches cannot be treated as sales without supporting material evidence. The income-tax authorities assessed sovereign transactions in the Bombay branch as sales to the Karachi branch and computed profit on that basis, but the record did not disclose evidence of a sale. The appellate authority accepted the assessee's case that the sovereigns were sent on commission, and the Tribunal adopted that view without independent reasoning. On those facts, the Court held that there was no material to support a finding that 1,66,188 sovereigns were sold to the Karachi branch, and the question of law arose from the absence of evidentiary support. en-us Mon, 07 Nov 1960 00:00:00 +0530 Mon, 01 Sep 2014 21:26:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=49451 Inter-branch despatches cannot be treated as sales without supporting material evidence. The income-tax authorities assessed sovereign transactions in the Bombay branch as sales to the Karachi branch and computed profit on that basis, but the record did not disclose evidence of a sale. The appellate authority accepted the assessee's case that the sovereigns were sent on commission, and the Tribunal adopted that view without independent reasoning. On those facts, the Court held that there was no material to support a finding that 1,66,188 sovereigns were sold to the Karachi branch, and the question of law arose from the absence of evidentiary support. Case-Laws Income Tax Mon, 07 Nov 1960 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=49451