Shyamal Kumar Sen, J. - (1.) The assessee is a company and the assessment year involved is 1964-65 for which the previous year ended on March 31, 1964. During the year, the assessee carried on the business of manufacture and sale of jute fabrics.
(2.) Bird and Co., during the year, were the managing agents of the assessee-company as also two other jute mills by name the Kinnison Jute Mills Co. Ltd. and Northbrook Jute Mills Ltd. and also of another company known as Becker Gray and Co. (1963) Ltd. (hereinafter referred as "Becker Gray"). Becker Gray acted as an export house for the export of wide hessian manufactured by the assessee-company and the other aforesaid two jute companies to the U. S. A. Becker Gray exported this wide hessian to the U. S. A. through Messrs. White Lamp and Finlay acting as agents.
(3.) For exporting the wide hessian, the assessee used steel cores for winding the said wide hessian into rolls.;