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2006 (3) TMI 735 - ALLAHABAD HIGH COURTExtract: .......ence, tax on the sale of such Oil was levied. This Court held that under Section 21, burden lies upon the Revenue to prove that in respect of the alleged goods, applicant was importer. This case is also distinguishable on the facts of the present case. 11. For the reasons stated above, revision is devoid of any merit and is, accordingly, dismissed.
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