TMI Blog1987 (2) TMI 514X X X X Extracts X X X X X X X X Extracts X X X X ..... f the Income-tax Act, 1961 ('the Act'). The following questions have been referred at the instance of the assessee : 1. Whether, on the facts and in the circumstances of the case, the Tribunal was right in holding that the assessee had business connection in India ? 2. If the answer to question No. 1 is in the affirmative whether, on the facts and in the circumstances of the case an ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... n behalf of the assessee at the hearing of this reference. Therefore, we decline to answer the questions which have been referred at the instance of the assessee. 4. So far as the question referred at the instance of the revenue is concerned, the same arises from the following observation in the decision of the Tribunal: We searched in vain in the records for finding out some basis for dete ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... in India. We feel that 10 per cent of what had been estimated by the Income-tax Officer as net profits of those years would be a proper estimate of the assessee's income that had accrued or arisen in India to be accordingly brought to tax. The Appellate Assistant Commissioner's order in all these cases will stand reversed to that extent. 5. The findings of the Tribunal as recorded in ..... X X X X Extracts X X X X X X X X Extracts X X X X
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