1986 (3) TMI 8

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..... er section 256(2) of the Income-tax Act, 1961, this court has directed the Tribunal to refer the following questions as questions of law arising out of the order of the Tribunal for the opinion of this court : (1) Whether, on the facts and in the circumstances of the case and on a proper construction of the agreement between the Indian company and the Export company, the Tribunal was right in ho .....

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..... 1964-65 ?" The controversies raised in the said questions are covered by the decision of this court in T.I. and M. Sales Ltd. v. CIT[ 1985] 151 ITR 286, being the case of the same assessee. Following the said decision, we answer question No. (1) in the affirmative and question No. (2) in the negative, both in favour of the assessee. There will be no order as to costs. Let the description o .....

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