Order

Manufacturers of buses, such as, TATA and Ashok Leyland get orders for export of buses. One such export order is annexed as "R-3" in the paperbook. These manufacturers manufacture chassis and they thereafter place orders on the assessee for building bus-bodies (See : annexure "R-5" in the paperbook). The name of the assessee in the present case is Azad Coach Builders Pvt. Ltd. The foreign buyers place an order on the exporter, namely, TATAs for supply of "the complete bus/buses" giving specifications of the chassis and the bus-body. In some cases, the foreign buyers even indicate the source from which the exporter in India should get the "bus-body" constructed. After constructing the bus-body as per the specifications and after completing the bus in its entirety, the assessee (body-builder) delivers "the complete bus" to TATA/Ashok Leyland who then exports the same to Sri Lanka for the purposes of accounting. The exporter raises a bill for chassis on the assessee and instead of making entries in the accounts by first debiting the value of the chassis to the body-builder (assessee) and then deducting the amount of chassis from invoice of a complete bus, the exporter invoices th