DIRECTOR OF INCOME TAX INTER. TAXATION vs. M/S MITSUI & CO. LTD.
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2003 .
Having heard learned counsel for the parties, we are of the view that the order of the Tribunal involves a substantial question of law.
Admit.
The following question is framed for adjudication: . "Whether the ITAT was correct in holding that the assessee company is not having permanent establishment in India and therefore exempt under the provisions of the agreement for Avoidance of Double Taxation between India and Japan?" . . .
The appellant shall file within three months ten copies of the cyclostyled paper books, containing all documents on which reliance was placed before the Tribunal, including any order/orders, either in the case of the assessee himself or in case of any ot her assessee, which has been followed by the Tribunal.
The appeal shall be listed for hearing in the regular course. . D.K. JAIN, J . . . MADAN B. LOKUR, J MAY 02, 2003 aa