Deb, J. - (1.) This reference under Section 256(1) of the I.T. Act, 1961, arises out of the assessment proceedings for the assessment year 1968-69.
(2.) The assessee is a private limited company. It carries on business of manufacture and sale, inter alia, of mild steel rods and bars used in reinforced concrete constructions or structures.
(3.) The assessee and M/s. Tor-Isteg Steel Corporation of Luxembourg (hereinafter referred to as "the foreign company") entered into an agreement dated February 15, 1967, In this agreement, the assessee has been described as the "licensee" and the foreign company as "Tor-Isteg".;