COMMISSIONER OF INCOME TAX Vs. BANK OF CHINA

JUDGEMENT

(1.) IN this application, the Commissioner of INcome-tax, West Bengal-IV, Calcutta, seeks a certificate from us that substantial questions of law of general public importance have arisen out of a judgment of this court dated February 20, 1985, delivered in the above INcome-tax Reference No. 182 of 1978, and that the same is a fit case for appeal to the Supreme Court.

(2.) THE question which was referred at the instance of the Revenue before this court in the reference is as follows :