WHETHER TRANSACTION BETWEEN London head office of the assessee and its branch in India tantamount to Sale ?

WHETHER TRANSACTION BETWEEN London head office of the assessee and its branch in India tantamount to Sale ?

Case: Betts Hartley Huett and Co Ltd vs Commissioner of Income Tax,West Bengal-II Calcutta

Facts  

 

 

 A Division Bench was concerned with a transaction between the London head office of the assessee and its branch in India. The question before the court was whether it was sale. The court held in construing the transaction that the head office and the branch office being parts of the same entity there could not be a sale by the head office to itself, that is, the branch office.