JUDGMENT

Bhamcha, J. - (Minority Opinion)

These appeals by special leave are filed by the assessee. They impugn the correctness of the judgment and order-of the High Court at Bombay dated 21st December, 1995 in respect of the Assessment Year 1976-77 and subsequent orders of the High Court following the fore stated judgment for the Assessment Years 1972-73, 1973,74, 1974-75, 1977-78, 1979-80 & 1983-84. The question that arose for consideration in references to the High Court under Section 256(1) of the Income Tax Act, 1961 read:

"Whether on the facts and in the circumstances of the case the Tribunal was justified in holding that oxford University, Press, Bombay, which is Part of Oxford University, is exempt under Section 10(22) of the Income Tax Act, 1961?"

The question was answered by the High Court in the negative and in favour of the Revenue.

2. The assessee is a branch of the Oxford

University Press, which, as the question itself notes, is a part of the University of Oxford in the United Kingdom. The assessee publishes books and carries on similar business in India. It was treated as a non resident company under the terms of a Notification issued by the Central Board of Revenue on 3