COMMISSIONER OF INCOME TAX Vs. PETROLEUM INDIA INTERNATIONAL

JUDGEMENT

(1.) In this appeal, though the Revenue has raised four questions of law in the appeal memorandum, only the following two questions are pressed for consideration:

(2.) The respondent-assessee is an Association of Persons consisting of nine public sector oil companies as its members. The respondent-assessee is engaged in doing business abroad and for that purpose deploys trained manpower to foreign companies at contracted rate.

(3.) Re.: Question (a)