Tribunal Missteps in Inter-Unit Transfer Case: Focus Should Be on Distinct Entities, Not Registrations or Business Lines.

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....Inter unit transfer of goods would constitute a sale or not - It is thus evident that unless and until there are two distinct entities, the question of sale may not arise. However, the Tribunal has not even addressed this issue and has misdirected itself in looking at the factum of independent registrations and independent lines of business to conclude that the alleged inter unit transfer would constitute sale. - HC....