Judgement

BACHAWAT, J.: These appeals arise out of proceedings for assessment of income-tax of the appellant Company (hereinafter referred to as the assessee) for the assessment years, 1943-44, 1944-45, 1945-46, 1946-47, 1947-48 and 1948-49, the relevant accounting years being the Calendar years, 1942, 1943, 1944, 1945, 1946 and 1947 respectively.

2. During the relevant accounting years, the assessee was a non-resident. It carried on the business of manufacturing textile goods at Indore then situated in an Indian State, and had officers at Indore and Bombay. The assessee supplied goods to the Indian Stores Department, Government of India, under purchase orders placed by the latter with the assessee at Indore. Duplicate copies of the purchase orders signed on behalf of the assessee at Indore used to be sent to the Government of India in British India. The goods used to be inspected at Indore by an inspecting officer of the Government and the inspection certificates were issued at Indore. One of the conditions of the contract was that the delivery would be F.O.R., Indore, and the freight from Indore would be borne by the Government of India. The goods used to be despatched by railway f