Mr. Justice P.V. Reddi, Chairman. - This application is filed by a non-resident Company under section 245Q(1) of the Income-tax Act, 1961 (hereafter referred to as ‘Income-tax Act’). The following facts are stated in the application :—

1.1 The applicant (hereafter referred to as ‘AIH’) is a company incorporated in the Kingdom of Bahrain. AIH is an investment company having investments in various Asian, European as well as Latin American companies. AIH is owned 99 per cent by South Arabian Amiantit Company ("SAAC"), listed on the Saudi Stock Exchange and 1 per cent by a trustee acting on behalf of SAAC. Amiantit Fiberglass Industries (India) Private Limited ("AFIIL") is an Indian company engaged in the production of glass reinforced polyester pipes, storage tanks etc. AIH holds 70 per cent of equity capital of AFIIL and these shares are held as investments in physical form. Amitech Cyprus Holding Limited ("ACHL") is a company incorporated in Cyprus and is a 100 per cent subsidiary of AIH. ACHL is an investment company and holds shares of various other group entities. The only income received by AIH from AFIIL is dividend. AIH does not have any other source of income from India