S. K. KULSHRESTHA, J.

( 1 ) THE first appeals from serial Nos. 1 to 13 under Section 260a of the IT Act, 1961, have been filed by the Department, the Dy. CIT (2) Ujjain, against the order dt. 15th July, 2003 of the Tribunal in various income-tax appeals in the case of M/s Turquoise Investment and Finance Ltd. , Nagda, and Trapti Trading and Investment Ltd. Since all these appeals raise similar questions, reference is being made to the facts contained in IT Appeal No. 96 of 2003. Insofar as the appeals of the assessees are concerned, being appeals from serial Nos. 14 to 26, the facts have been taken from IT Appeal No. 112 of 2003 which are common to all appeals.

( 2 ) THOUGH the appeals filed by the Department have raised a large number of questions, the appeals have been admitted on the following questions of law:1]. Whether Tribunal was justified in holding that dividend income earned by the assessee amounting to Rs. 21,35,766 from a company called Pan Century Edible Oils SDN. , BHD. Malaysia, is not liable to be taxed in the hands of assessee in India under any of the provisions of the IT Act? 2]. In view of Section 5 (1) (c) of the IT Act, whether the finding recorded by the Tri

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