Judgment :- R. JAYASIMHA BABU, J. Counsel for the Revenue submits that Civil Appeals Nos. 5751-5757 of 1997 is pending in the Supreme Court on identical issues. Having regard to that submission, and also having regard to the fact that the issue raised is one of general importance concerning as it does, the interpretation of the provisions of the agreement concerning relief from double taxation between India and Malaysia, the certificate sought is granted.