1. The applicant before us is Section M. Modi who produced the picture Jhansi-ki-Rani. For the purpose of this production he had employed two foreigners Ernest Haller and Forrest Judd. They arrived in India in September and November, 1951 respectively. Mr. Modi had paid remuneration to these employees in the sums of Rs. 1,31,520/- and Rs. 33,478/- respectively in the two accounting years 1951-52 and 1952-53. If these foreigners were not resident in India during the accounting years, Mr. Modi was under a liability to deduct income-tax at the maximum rate from the salary paid to these em-ployees at the time of payment by reason of Section 18, Sub-section (3A). Mr. Modi failed to do so. The Income-tax Officer was of opinion that these two employees were not resident in the taxable territories and directed Mr. Modi to pay income-tax and supertax with appropriate surcharge in the case of both these foreigners. The demand was not paid; and Mr. Modi filed two appeals one in each case to the Appellate Assistant Commissioner. These two appeals were held to be not competent on the ground that the only right of appeal that Mr. Modi could have was under Section 30 (1A), and the conditi