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1981 (9) TMI 97 - HC - Income TaxExtract: .......show that cl. 5(ii) of the agreement of collaboration could not by itself be construed as being a contract of sale and purchase between KOEL and the assessee and that the situs for such a contract of sale of material to the assessee was outside India. In the result, we answer the question in the negative on both parts and in favour of the assessee.
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