TMI Blog2017 (12) TMI 1586X X X X Extracts X X X X X X X X Extracts X X X X ..... hat the details were considered not only by the Assessing Officer but also by CIT (Appeals). This is purely a finding of fact recorded by the Appellate Tribunal. In fact, in paragraph 22, it is reiterated that the authorities had examined various details and had come to a different conclusion. The findings which we have quoted above are not shown to be perverse. Hence, no substantial question o ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... , the Appeal was dismissed. Being aggrieved by the said order, an Appeal was preferred by the respondent assessee before the Income Tax Appellate Tribunal which has been allowed. 2 The learned counsel appearing for the appellant invited our attention to the finding recorded in paragraph 23 (first paragraph 23) of the impugned judgment. According to him, the finding is that the Assessing Offic ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... In paragraphs 22 and 23 on the same page, the following findings have been recorded which read thus : 22. In the current proceedings also, the revenue authorities examined those vary details to come to a different conclusion. This, in our view, the case would in the clearly fall within the ratio laid down Hon'ble Delhi High Court in the case of CIT vs Kelvinator of India, reported in 256 ..... X X X X Extracts X X X X X X X X Extracts X X X X
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