M/S JAPAN AIRLINES CO.LTD. vs. COMMR.OF INCOME TAX,NEW DELHI

D G M E N T A.K. SIKRI, J. In these appeals, the issue involved relates to the deduction of tax at source ('TDS'). In both the cases, assessees are foreign Airlines. One is Japan Airlines Company Limited (hereinafter referred to as the 'JAL') and the other is Singapore Airlines Limited (hereinafter referred to as the 'SAL'). As both