MINERAL AND METAL TRADING CORPORATION vs R. C. MISHRA AND ORS.

The Supreme Court held that under Section 280ZC of the Income Tax Act, 1961, M.M.T.C. is the exporter for tax credit purposes as the entire export was conducted through it in accordance with the barter system. The Court emphasized that the statutory documents executed in M.M.T.C.'s name cannot be disregarded as mere appearances. The High Court's ruling that Ferro Alloys was the real exporter was overturned, affirming that M.M.T.C. held the title to the goods and thus qualified for the tax credit certificate.