The companytention of the assessee is that the oil which was purchased by the assessee from foreign companyntries on the strength of the import entitlement was at a rate much lower than the rate obtaining in the Indian market for similar products.
Since the assessee paid a lower price for the imported palm oil the assessee made a larger profit than what it would have made had it purchased palm oil locally at a higher rate.
The assessee, therefore, would be entitled to benefit of Section 2 5 i of the Finance No.
It utilised the import entitlements in purchasing palm oil from foreign companyntries.
The particulars of the products manufactured by the assessee utilising palm oil have number been given in the order of the Tribunal.
The imported palm oil was companysumed internally by the assesses for manufacturing other products.
However, for the exports made at a loss, the assessee was rewarded with import entitlements.
The assessment years involved in these matters are 1962 63 and 1963 64.
The assessee had also exported groundnut oil which resulted in an apparent loss of Rs.
The assessee is a manufacturing companypany.
In the relevant years of account, it made large profits.
3,44 lakhs.
