Substantial questions of law on branch profits, capital gains and section 90(3) notification led to appeal admission.

The appeal concerned whether substantial questions of law arose on the inclusion of branch profits and capital gains in India, and on the scope and applicability of a notification issued under section 90(3) of the Income-tax Act, 1961. The HC admitted the appeal on the substantial questions of law. Questions (iii) and (iv) were not pressed by the appellant.

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Issues: Whether the appeal raised substantial questions of law on inclusion of branch profits and capital gains in India, and on the scope and applicability of the notification issued under section 90(3) of the Income-tax Act, 1961.

Outcome: The appeal was admitted on the substantial questions of law; questions (iii) and (iv) were not pressed as stated by the appellant.

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