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2003 (10) TMI 43 - PUNJAB AND HARYANA HIGH COURTThe question that arises in this case is whether the arrangement arrived at between the parties was not genuine and whether it had been adopted only with a view to deprive the Revenue of the tax due or was it a genuine arrangement. The Tribunal as also the Commissioner of Income-tax (Appeals) accepted the explanation and found as a fact that the arrangement was genuine and there was no intention to hoodwink the Revenue. This is a pure finding of fact arrived at by the income-tax authorities and no question of law much less a substantial question of law arises from the impugned orders.
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