1982 (11) TMI 161

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....ler and exporter in hides and skins. During 1975-76, he exported hides and skins through several agents. The records showed that the transactions between the assessee and the agents were not as between principal and principal for but the latter were appointed specifically as agents for export. The books of the assessee showed that they were credited with commissions. The books further showed that ....

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....in order that the transactions may be treated as direct sales by the assessee to the so-called agents, treating the latter as principals. The orders of the Appellate Assistant Commissioner cannot be supported at all. The argument of learned Government Pleader was sought to be put forward only on the basis of the reasonings contained in the orders passed by the Appellate Assistant Commissioner. ....