(1.) THIS is a reference on the motion of the assessee by the Tribunal, Madras Bench, under s. 66(1) of the Indian IT Act, 1922. The question referred reads as follows :
(2.) THE assessment year concerned is 1960-61. During the accounting period relevant to that assessment year, the twelve months ended on 31st March, 1960, the assessee's income from business in Ceylon was Rs. 18,765. The IT authorities in Ceylon assessed the said income under the Ceylon IT Ordinance, 1932, granted the assessee the reliefs to which he was entitled under that Ordinance and fixed the amount of tax payable by him at Rs. 704. It is common ground that the said tax has been paid.
(3.) THE notification on the subject is Notification No. S.R.O. 456, dt. the 6th Feb., 1957. The notification is reprinted in Kanga's Law and Practice of Income-tax, 4th edition, volume II, on pages 330 to 334. Art. III of the agreement--the article referred to in the question referred--reads as follows :