From the Judgment and Order dated 24.3.87 1.7.87 of the Andhra Pradesh High Court in Writ Petition No.
A. Palkhivala, P.A.S. Rao, D.N. Mishara, Ranganatha Chari and Ms. Rubi Anand for the Petitioners.
This was followed by an agree ment dated 2 May, 1986 executed at Hyderabad.
C. Manchanda, Ms. A. Subhashini and B.B. Ahuja for the Respondents.
105 8737 of 1987.
The companysideration for the technical know how and technical services was represented by Norwegian currency NOK 32 Millions equivalent to about Rs.575 lakhs.
CIVIL APPELLATE JURISDICTION Civil Appeal No.
These appeals by Special Leave are directed against the dismissal by the Andhra Pradesh High Court of Writ Petitions filed by the appellant.
The Judgment of the Court was delivered by PATHAK, C J Special Leave granted.
It is number in dispute that the agreement had received the careful companysideration of the Reserve Bank of India and of the Central Government.
2697 2698 of 1989.
Eighty five per cent of the companysideration was to be paid from credit provided by Norwegian authorities and the balance fifteen per cent was to be paid out of free foreign exchange made available by the State Bank of India, London Branch.
The appellant, Messrs Electronics Corporation of India Limited, entered into a memorandum of understanding with a Norwegian companypany at Paris.
The appellant approached the Income Tax Officer for the grant of a No Objection Certificate as companytemplated under s. 195 2 of the Income Tax Act, 1961, to enable it to remit the instalments due without any obligation to deduct any income tax at source, but the request was denied.