MYSORE KIRLOSKAR LIMITED Vs. COMMISSIONER OF INCOME TAX

JUDGEMENT

(1.) THIS is a reference under section 66 (1) of the Indian Income -tax Act, 1922, to be hereinafter referred to as the 'Act'. The said reference was made by the Income -tax Appellate Tribunal, Bombay Bench, at the instance of the assessee. The question of law referred for the opinion of this court is :

(2.) THE assessee, the Mysore Kirloskar Limited, is a company manufacturing machine tools, workshop equipment, etc.

(3.) CLAUSE 12 of the agreement is the most important clause for our present purpose. It reads thus :