( 1 ) M/s. Premnath Dieselsgrainvaying Division, a partnership firm constituted on 2-4-1969entered into a contract with a non-resident company M/s International Grain Vaying Company Incorporated which was incorporated in U. S. A. This contract was in connection with the operation in India of off-loading the grain from large tonnage vesselsto the smaller ships along the Indian Coastline and providingsuitable grain vayors and their operation for discharge of wheatfrom large vessels to the smaller ships: M/s. Premnath Dieselsgramvaying Division was to provide necessary supervisory andother staff for maintenance and operation of such grainvayors. M/s. Premnath Diesels Grainvaying Division ultimately dissolvedon 1-4-1971. On 11-1-1972 the Income-tax Officer made anassessment for the assessment year 1969-70 on the non-residentcompany namely; M/s. International Grain Vaying Companyincorporated on a total income of Rs. 2,75,000 on the basis ofreturn filed by the non-resident company. It appears that thenon-resident company subseqwntly closed its business in Indiaand its Managing Director and Director left India for New York. Thereafter, on 6-12-1972 the Income-tax Offic