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1973 (6) TMI 4 - HC - Income TaxA rule nisi has been served upon the assessee calling upon it to show cause why the three questions referred to therein should not be made a subject-matter of the reference and why the rule nisi should not be made absolute - Whether the question, if an income is attributable to operations in India is one of fact and whether a reference lies to High Court on the Tribunal finding that no income was attributable to operations in India - In our opinion, that finding is not correct and the Tribunal on the material on record clearly came to the conclusion that it has not been established in this case that any of the operations are carried out in India, the income in respect of which is sought to be assessed - There is no question of law for a reference to the High Court
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