Judgment :- R. JAYASIMHA BABU, J. Counsel for the Revenue submits that Civil Appeals Nos. 5751-5757 of 1997 are pending in the Supreme Court on identical issues. Having regard to that submission and also having regard to the fact that the issue raised (Whether, on the facts and circumstances of the case, the Tribunal's decision that the entire income arising in Malaysia is not includible in total income and cannot be subjected to tax in India, is in accordance with the Agreement for Avoidance of Double Taxation entered into between the Government of India and Malaysia ?) 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.