Remand after earlier tribunal precedent was set aside, with reassessment and India-source income issues sent back for fresh consideration.

Where the Tribunal's appellate orders were founded on an earlier decision that had since been set aside by the High Court, those orders could not be sustained and had to be restored for fresh disposal. The Court also declined to answer the Tribunal's referred questions on reassessment under section 147 and on whether the non-resident's income accrued or was earned in India. The matters were remitted to the Tribunal to reconsider the appeals in accordance with law and in light of the High Court's decision in Fertilizers and Chemicals (Travancore) Ltd.

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Outcome: The references were declined and the Tribunal was directed to restore the appeals to its file and decide them afresh in accordance with law and the earlier decision of the Court.

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