Allowing the appeal of the revenue the Court held that ; the newspapers, in all respects, were identical. The quality of paper used, the printing material and the cost of each such newspaper sold in Ahmedabad as well as outside Ahmedabad were the same. Under the circumstances, the most fair and equitable means of dividing the income between the two units would be in the proportion of their internal publication and circulation of the Ahmedabad edition. That was what the Assessing Officer had done. The Assessing Officer’s order was justified. ( AY.1989-90)