S.K.DAS, J.

(1) THESE are two appeals on a certificate of fitness granted by the High Court of Judicature at Bombay under s. 66A(2) of the Indian Income-tax Act, 1922. The relevant facts which have given rise to them are shortly stated below.

(2) THE Indore Malwa United Mills, a limited liability company, is the appellant before us and will be referred to in this judgment as the assessee company. The respondent is the Commissioner of Income-tax(Gentral), Bombay. The assessee company carried on a business of manufacture and sale of textile goods. The manufacture was made at its mills in Indore which was Indian State before integration and had its own law as to income-tax known as the Indore Industrial Tax Rules, 1927. The sales of textile goods were made at various places, some inside and some outside the taxable territories of British India. For and upto the assessment year 1949-50 the assessee company was treated as a non-resident within the meaning of s.4A of the Indian Income-tax Act, 1922. For the assessment years 1950-51, and 1951-52 which are two assessment years under consideration, the account years were the calendar years 1946 and 1950 respect