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2003 (10) TMI 43 - HC - Income TaxThe 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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