( 1 ) THE petitioner in this application is the Assam Consolidated Tea Estates Ltd. (hereinafter referred to as the "english Company"), a company incorporated in England, which used to carry on business in the manufacture and sale of tea in India and Pakistan and owned several tea estates in these two countries and was assessed in respect of the income therefrom up to the 31st March, 1957. For carrying on the business more conveniently, the petitioner transferred its Indian assets including the tea estates situated in India to Assam Consolidated Tea Estates (India) Ltd. (hereinafter referred to as the " Indian company "), incorporated in the U. K. for that purpose with effect from the 1st April, 1957. The Indian company was a 100% subsidiary of the English company. The consideration for the transfer of the assets to the Indian company was 6,77,001) and the consideration was satisfied by the allotment to the English company of 4,77,000 ordinary shares of 1 each in the Indian company and the balance of 2,00,000 by the issue of unsecured loan stock of that amount bearing interest at 6% per annum. For the assessment year 1957-58, the petitioner filed its return showing i