Commissioner Of Income-Tax vs Vr. S.R.M. Firm And Others on 15 March, 1994
4. Counsel for the Revenue made an oral application for a certificate of fitness for appeal to the Supreme Court. Having regard to the fact that the questions involve the interpretation of an international treaty, the questions are of general importance and the questions involved are substantial questions of law with regard to the extent of the benefits conferred on the assessee in India in terms of that agreement, we grant the certificate sought. The questions need to be decided by the apex court. We do so also in the light of the fact that Civil Appeals Nos. 5751 to 5757 of 1997 are pending in the apex court against the decision of this court rendered in the case of CIT v. VR. S. R. M. Firm [1994] 208 ITR 400.