COMMISSIONER OF INCOME TAX Vs. SULZER BROTHER LIMITED

JUDGEMENT

(1.) THESE tax case petitions, at the instance of the Commissioner of Income-tax, Tamil Nadu-V, Madras, are for issuance of a direction to the Tribunal to state a case and refer the common question of law, as below, for the opinion of this court :

(2.) SECTION 9 of the Income-tax Act, 1961 (Act No. 43 of 1961) for short ("the I. T. Act"), deals with a situation, when income is deemed to accrue or arise in India. So far as the instant case is concerned, we are concerned with SECTION 9(1)(vii) of the Income-tax Act, which reads as under :