Dipak Kumar Sen, J. - (1.) The material facts and proceedings leading up to the above references are, inter alia, that Messrs Hoare Miller & Co. Ltd., Calcutta, the assessee, is a company. The assessee is a leading exporter of jute products. In its business, the assessee at the material time used to issue firm offers by cables to its foreign customers for supply of jute products by way of exports. These offers were kept open for 24 to 72 hours and on receipt of the acceptance by the foreign customers, the assessee exported the jute products.
(2.) Against the offers made to its foreign customers, the assessee used to enter into purchase agreements with local suppliers in order to guard itself against future price fluctuations in the jute market. In most of the cases, the assessee used to enter into a purchase transaction locally against each export offer abroad.
(3.) The firm offers issued by the assessee to its foreign customers abroad were accepted in or about 80% of cases and the balance of about 20% did not materialise in any concluded contract.;