Ajit K.Sengupta, J. - (1.) In this reference under Section 256(1) of the Income-tax Act, 1961, at the instance of the assessee, the following question of law has been referred by the Tribunal for the opinion of this court for the assessment year 1978-79 : "Whether, in the facts and circumstances of the case, the assessee was entitled to deduction of 50% of the tax charged in India in respect of its shipping business as provided in article VI of the Agreement for Avoidance of Double Taxation between India and Greece"
(2.) The facts leading to this reference are stated hereafter.
(3.) The two assessee-companies are non-resident shipping companies incorporated in the Republic of Panama. The assessee-companies have no business apart from shipping business.;