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2006 (1) TMI 78 - PUNJAB AND HARYANA HIGH COURTAOP - "1. Whether, Tribunal was right in dismissing the appeal of the Revenue by holding that the payment was made by Shri Kulwant Singh, although the facts as found for the Commissioner of Income-tax (Appeals) in order dated October 8, 1992, for the assessment year 1989-90 were different? 2. Whether, Tribunal was justified in holding that no association of persons was in existence when it is undisputed that payment to Excise authorities was made on behalf of three persons (Sh. Kulwant Singh, Sh. Balbir Singh and Sh. Daljit Singh) who later on formed a firm with effect from April 1, 1988? 3. Whether the order of Tribunal was perverse as it was based on unsupported version of the assessee?" - The finding recorded by the Tribunal is a pure finding of fact, giving rise to no question of law, much less a substantial question of law
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