C O M M O N J U D G M E N T

(Judgment of the Court was delivered by N.KIRUBAKARAN, J)

Delink from T.C.A.Nos.89, 92 & 100 of 2020. T.C.A.No.94 of

2020 has been preferred by the Revenue against the order of the Income Tax Appellate Tribunal, Madras “C” Bench, dated 14.03.2018 in ITA.No.1422/Chny/2016.

2.T.C.A.No.95 of 2020 has been preferred by the Revenue against the order of the Income Tax Appellate Tribunal, Madras “C” Bench, dated 14.03.2018, CO No.92/Chny/2016 in ITA.No.1420/Chny/2016.

3.T.C.A.No.101 of 2020 has been preferred by the Revenue against the order of the Income Tax Appellate Tribunal, Madras “C”

Bench, dated 14.03.2018 in ITA.No.1420/Chny/2016.

4.T.C.A.No.104 of 2020 has been preferred by the Revenue against the order of the Income Tax Appellate Tribunal, Madras “C” Bench, dated 14.03.2018, CO No.93/Chny/2016 in ITA.No.1422/Chny/2016.

5.These appeals are admitted on the following substantial questions of law :

“(i)Whether on the facts and in the circumstances of the case, the Tribunal was right in holding that the income of the assessee from sources outside Malaysia cannot be taxed in India, though the assessee is a resident in India and the control and management of the Mala