2001 (9) TMI 5

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....61 222 ITR 534) which had dismissed the writ petition filed by the appellants wherein challenge was made to the show-cause notice dated May 16, 1996. The aforesaid show-cause notice was issued on the allegation that salary had been paid to four employees who were working with the appellants in India. These employees were Japanese and the salary in question had been paid by a Japanese-company in ....

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.... had filed returns of income in respect of the four employees in question and had paid the entire amount of income-tax payable in respect of what was paid to these four employees in Yen currency. This and the other facts cannot be taken up for consideration by this court for the first time. In our opinion, the High Court was right in coming to the conclusion that it is appropriate for the appell....