Judgment

HEGDE, J.:- The first two appeals have been brought by certificate and the other two by special leave. The later tow appeals came to be filed because the certificates on the basis of which the earlier appeals were brought were found to be defective inasmuch as the High Court had not given any reason in support of those certificates. Hence it is sufficient, if we deal with the latter two appeals.

2. The appellant is a non-residence British Shipping Co. whose ships ply in waters all over the world including the Indian waters. For the assessment years 1960-61, and 1961-62 (the relevant accounting years being calendar years 1959 and 1960), the Income-tax Officer, computed its total income taxable under the Indian Income-tax Act, 1922 (which will hereinafter be referred to as the Act) by taking into account the ratio certificates issued by the Chief Inspector of Taxes, U. K. which were based on the assessments made on the appellant in U. K. During the relevant period, there was in U. K. "investment allowance" corresponding to "development rebate" under the Act. The certificates issued by the Chief Inspector contained the percentage ratio of the total world profits of the appellan