Situs of owner of intangible asset, would be closest approximation of situs of intangible asset

M/s. Lal Products Vs Intelligence Officer (Kerala High Court) Hon’ble Kerala High Court had an occasion to determine the situs of sale of incorporeal goods namely, patents and trademarks when the contract of sale was executed by the Appellant in the state of Gujarat where they had one operating manufacturing plant while the HO of the Appellant was in the state of Kerala. The High Court while distinguishing the decision of Gujarat High Court in case of Ambalal Sarabhai Enterprise Ltd. and relying upon the decision of Delhi High Court in case of CUB PTY Limited v. UOI and Ors. held that situs ...