1998 (11) TMI 64

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....J.--The questions referred to us at the instance of the Revenue, involved the interpretation of the agreement between the Government of India and the Government of Malaysia regarding the avoidance of double taxation and several matters. The assessment year is 1978-79. The questions referred are : "(1) Whether having regard to the articles 6, 7, 11, 12 and 22 of the Agreement of Avoidance of Dou....

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....rities was not a condition for relief ignoring the fact that what is included in the Indian assessment need not necessarily form part of computation in the Malaysian assessment (vide adjudgment laid down in article 22.2(b) ? (3) Whether, having regard to article 7.3 of the agreement, the Tribunal is in law, correct in concluding that capital gains arising from the sale of immovable property in ....