Judgement

S. R. DAS J- This appeal arises out of six references made by the Calcutta Bench of the Income-tax Appellate Tribunal under Sec. 66(1) Income-tax Act, two of them relating to the Income tax assessment years 1943-44 and 1943-45 and the remaining four relating to Excess Profits Tax for the chargeable accounting periods on 31st December of each of the years 1940, 1941, 1942 and 1943 respectively.

2. The relevant facts appearing in the statements of the case are as follows: Messrs. Port Said Salt Association Ltd., (hereinafter referred to as "the Association") is a company incorporated in the United Kingdom and has its registered office there. The Association, however, carries on business in Egypt and its head office is situate in Alexandria where the annual general meetings of its share-holders are held. Not being resident in the United Kingdom the Association pays no British Income-tax, an its profits. For the purposes of assessment under the Indian Income-tax Act, the Association has been considered to be a non-resident. The Association manufactures salt in Egypt where it has certain concessions and the salt as manufactured is sent for sale in any country where there is a su