the profit from assessees manufacturing business in pakistan was companyputed at rs.
from the judgment and order dated 8 7 1971 of the calcutta high companyrt in i.t.r.
the income tax officer deducted by way of set off the agricultural loss of rs.
for the relevant year the assessees indian income as companyputed by the income tax officer was rs.
201702/ .
the corresponding previous year of the companypany ended on june 30 1955.
this is an appeal by certificate and in it is involved an important question of law as to the interpretation of article iv of the agreement for avoidance of double taxation in india and pakistan hereinafter called the agreement.
320839/ against the profit of the manufacturing business amounting to rs.
320839/ .
the companycerned assessment year is 1956 57.
in respect of the agricultural property however there was loss and it was determined at rs.
civil appellate jurisdiction civil appeal number 2097 of 1978.
the following judgments were delivered untwaliaj.
the only case on the point decided by any companyrt in india so far brought to our numberice is the decision of the calcutta high companyrt which is under appeal reported in companymissioner of income tax west bengal iii v. carew company limited 1 carew companypany limited the respondent in this appeal was resident in india having its registered office in calcutta.
c. manchanda s. p. nayar and miss a. subhashini for the appellant.
373/ from interest on securities.
the total of the two items was rs.
k. sen d. n. gupta and t. a. ramachandran for the respondent.
number 35/67.
326368/ .
during the relevant period the sources of income of the respondent companypany were from a business in india and interest earned in india on securities b manufacturing business in pakistan and c agricultural properties in pakistan.
201329/ from business and rs.
