CLIFFORD CHANCE Vs. DEPUTY COMMISSIONER OF INCOME TAX

JUDGEMENT

(1.) These appeals are filed by the assessee under Section 260A of the Income-tax Act, 1961 (hereinafter referred to as "the Act" for short) against the orders of the Income Tax Appellate Tribunal("ITAT" for short) both dated 27th September, 2001 in I.T.A.Nos. 1327 and 1328/Mum/2001, whereby the appeals filed by the assessee against the orders of the C.I.T.(A) both dated 19.12.2000 which were dismissed, were admitted for final hearing on the following substantial questions of law.

(2.) The factual scenario common to both appeals arising out of the orders relating to the Assessment Years 1996-97 and 1996-97, lies in narrow campass. The facts are drawn from Appeal No. 1327/Mum/2001 relating to the Assessment Year 1996-97 for the sake of clarity. Both the appeals are being disposed of by this common order. The appellant is an international firm of solicitors resident in the United Kingdom (UK). It has no office or fixed base in India.

(3.) The appellant, during the previous year ended on March 31, 1996 (relevant to the Assessment Year 1996-97), was appointed as English law legal advisers for three projects in India, namely :