Aftab Alam, J.

1. In this set of seven connected cases relating to the assessment years 1975-76 to 1980-81, a common question of law has been referred to this court by the Income-tax Appellate Tribunal under Sec. 256(2) of the Income-tax Act, 1961, on a direction given by the Supreme Court at the instance of the assessee. The question of law on which decision is to be given by this court was framed by the Supreme Court in the following terms :

"Whether, on the facts and in the circumstances of the case, the Tribunal was right in holding that the income mentioned in article III(a) of the collaboration agreement accrued or arose in India to Wean United within the meaning of Sec. 5(2)fb) of the Income-tax Act, 1961 ?"

Hindustan Steel Limited, a Government of India undertaking (which was in existence at that time), entered into an agreement with United Engineering and Foundry Company, U.S.A., for acquisition of technical know-how for the design and manufacturing of rolling mills and auxiliary equipment. The "collaboration agreement" being the subject-matter of this reference was executed in India on February 11, 1969, on behalf of Hindustan Steel Limited. It came into effect on