Certificate for appeal granted on a treaty interpretation issue of general importance with parallel Supreme Court proceedings.

A certificate for appeal was granted where the dispute raised a question of general importance concerning interpretation of the India-Malaysia double taxation relief agreement, and identical issues were already pending before the Supreme Court. On that basis, the matter was treated as suitable for further consideration at the Supreme Court level, and the requested certificate was issued in favour of the Revenue.

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Issues: Whether the certificate sought for appeal should be granted in view of the pending civil appeals on identical issues and the general importance of the question concerning interpretation of the double taxation relief agreement between India and Malaysia.

Analysis: The certificate was sought on the basis that identical issues were already pending before the Supreme Court and that the question involved had general importance. On that footing, the request was considered suitable for grant.

Conclusion: The certificate sought was granted in favour of the Revenue.

Final Conclusion: The proceeding resulted in grant of the requested certificate, enabling further consideration of the question at the Supreme Court level.

Ratio Decidendi: Where an issue is of general importance and identical matters are already pending before the Supreme Court, a certificate for appeal may be granted.

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