1969 (11) TMI 72

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....is Messrs International Cotton (Waste) Corporation, Bombay, which is a partnership firm having its head office in Bombay and a branch office at Bhatinda. The main business of the firm is to buy cotton and cotton waste and to export it outside India. The cotton and cotton waste is generally purchased from the States of Punjab and Rajasthan. The firm is registered under the Punjab General Sales Tax ....

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....arned assessing authority was of the opinion that the sale of cotton had taken place at Bhatinda as the Bhatinda branch office simply transferred the goods to the head office, Bombay, which exported it to countries outside India. Since the branch office did not export the cotton to countries outside India, the deduction was not allowable. This reasoning was not accepted by the learned Single judge....