UCO BANK Vs. INCOME TAX OFFICER

JUDGEMENT

(1.) The point involved in this writ petition is very short. The facts, however, are complex. In order to appreciate the issue involved it is necessary to recount the facts in some detail.

(2.) On June 4, 1966, the petitioner entered into a contract with Hindusthan Motors Ltd. for sale of 932,617 at the rate of Rs. 13.33 : 1. This was to cover contracts for import of goods which had been entered into by Hindusthan Motors. On the same day, the petitioner entered into three separate contracts with the Reserve Bank, Chartered Bank and the Bank of India for purchase of foreign exchange totalling 832,000, The balance of the 932,617, namely, 100,617, was to be met by the petitioner from its own resources.

(3.) These purchases were also made by the petitioner from the said bank at the rate of Rs. 13.33 : 1.