KEJRIWAL ENTERPRISES Vs. COMMISSIONER OF INCOME TAX

JUDGEMENT

(1.) Three assessment years are involved in this appeal under Section 260A which we have entertained. Those are assessment years 1991-92, 1992-93 and 1993-94. The facts which give rise to the appeals are briefly as follows.

(2.) The assessee-partnership firm, got into a joint venture collaboration agreement with a company of U. S. S. R., at a time just before the disintegration of the United Soviet Russia.

(3.) The agreement was in writing and the basic terms of the agreement were, that a company would be floated by the two parties, and capital would be contributed by the assessee to the extent of 60 per cent. and the Russian party to the extent of 40 per cent.