( 1 ) THIS appeal by the appellants, Indo Asahi Glass Company Ltd. , and Shri Purnendu Narain Roy, director of Indo Asahi Glass Company Limited, is against the judgment and order dated July 18, 1996, in C. O. No. 8405 (W) of 1996, passed by the learned single judge of this court disposing of the writ application filed by the appellants challenging the legality and validity of a show-cause notice, dated May 16, 1996, issued by respondent No. 1, Income-tax Officer (TDS), Ward-21 (1), Calcutta.

( 2 ) THE appellants have entered into a collaboration agreement with Asahi Glass Company Ltd. , a company incorporated in Japan, with regard to manufacture of sheet glass in India. The collaboration agreement was executed on May 20, 1983, between the appellants and the aforesaid Asahi Company Ltd. It appears that the appellants engaged some Japanese nationals as their technical personnel for manufacturing operations and also obtained the requisite permission from the Government of India and the Reserve Bank of India for such engagement of foreign nationals and for regulating their terms and conditions, including the payment of salary and other perquisites. It appears that som