Delay in obtaining the finality certificate from the Ceylon income-tax authorities.

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..... Ceylon, pending conclusion of a double taxation avoidance agreement between the two countries. The relevant portion runs as below:- "....the assessment orders of Ceylon should ordinarily be accepted subject to such adjustments as may be called for on account of difference in the provisions of the Indian Income-tax Act and the Ceylon Income-tax Law". Relying on the above instructions, double In .....

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..... re is delay in obtaining the finality certificate from the Ceylon income-tax authorities beyond the period of one year mentioned in Article V of the Agreement with Ceylon, payment of tax relatable to the doubly taxed income may be kept in abeyance by the Income-tax Officer if the assessee adduces proper evidence to show that failure to produce the relevant certificate did not arise due to any negl .....

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