COMMISSIONER OF INCOME TAX Vs. ASSOCIATED INDIA EXPORTS

JUDGEMENT

(1.) THE petitioner seeks reference of the following three questions to this Court :

(2.) IN our opinion, question No. 1 is a pure question of fact and r. 6B is, on the face of it, not applicable because that rule applies to expenses incurred on advertisement. The finding of fact in this case is that, to a foreign customer, a carpet worth Rs. 3,000 was presented. This surely is not a case of advertisement on behalf of the assessee when, admittedly, the assessee earns a lot of income from its foreign customers.