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2003 (11) TMI 34 - HC - Income TaxWhether the Assessing Officer has rightly made addition on account of notional interest on the debit balances of M/s. Jai Mangal Investment and Trading Co. and M/s. Banswara Textile Mills Ltd.? - As the finding reached by the Tribunal is a finding of fact about the existence of circumstances which would have caused genuine difficulty to the payee and such finding is ordinarily a finding of fact which does not give rise to a question of law. As the condition envisaged u/r 6DD(j) as was operating during the relevant assessment year has been shown to exist by the assessee and found by the Commissioner of Income-tax (Appeals) as well as the Tribunal to exist on cogent material that payment in the manner prescribed u/s 40A(3) would have caused many difficulties to the payee, is not vitiated on any ground and does not give rise to a substantial question of law for consideration in this appeal.
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