1959 (9) TMI 41

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....11-2, It was common ground that this represented the price at which the assessee purchased untanned hides and skins. The further findings were that these untanned hides and skins were got tanned in other tanneries by the assessee, and that the tanned hides and skins were eventually sold by the assessee for purposes of export. The Tribunal, agreeing with the departmental authorities, held that the ....

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....None the less, it was certainly a reasonable inference from the facts proved, that the Tribunal confirmed, that it was as a registered tanner that he purchased the goods. The fact that he had them tanned within the State at tanneries that did not belong to him did not make him any the less a registered tanner within the meaning of rule 16(2). Learned counsel for the assessee next contended that....

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.... sales of tanned hides and skins, because no tannery of his paid the tax within the meaning of rule 16(3). This contention again was not put forward before the Tribunal. Learned counsel for the assessee recognised as a factual position that on the sales of the tanned hides and skins the assessee was not subjected to any tax liability. The word "tannery" as used in rule 16(3) has to be considered c....