- (1.) These appeals by the grant of special leave are directed against a common order of the High Court in Income-tax Reference Nos. 87 and 88 of 1974 in terms of the order of Reference by the Income-tax Appellate Tribunal, Delhi Branch in respect of Assessment Years 1964-65 and 1965-66.
(2.) The Tribunal has referred the following two questions to the High Court for the above-mentioned assessment years 1964-65 and 1965-66.
(3.) For the assessment year 1964-65 the question reads as below : "Whether on the facts and in the circumstances of the case, Income-tax Appellate Tribunal was right in holding that the profit arising from the working of the two cement factories situated in Pakistan for the year 1-10-1962 to 30-9-1963 was taxable in the hands of the applicant-company -;