TaxTMI 
TaxTMI 
1972 (10) TMI 109
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.... their non-resident principal, the Titaghur Paper Mills Company Limited, Calcutta, in respect of sales of paper said to have been effected by them. The respondents, however, contended before the assessing as well as the appellate authority that the sales of paper have been effected directly by their principal, the said paper mills, to the various purchasers in this State and that the mere fact that they have taken delivery of the consignment and distributed the same to the various purchasers will not make them sellers in respect of those sale transactions. The respondents' claim that they have not effected any sales to the purchasers in this State and that it is only the paper mills which sold the goods in question to various purchasers in ....
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....r mills manufacture the required quantity of paper as per the various indents. After the required quantity of paper is manufactured, they are packed in several packages with the distinct marks of various dealers who had already placed orders. But all those packages had been clubbed together and sent to the respondents in one wagon, the railway receipt being taken in the name of the respondents. The relevant invoices along with the railway receipt are sent by the paper mills to the respondents and the mills had debited the various dealers with the value of the paper sent. After the wagon reaches this State, the respondents cleared the goods and delivered the several packages to the concerned dealers and collected the amounts due by them as p....