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2013 (12) TMI 1600 - HC - Income TaxRevision u/s 263 - Held that:- Once the Tribunal had come to the conclusion that the loan advanced was on account of commercial expediency as well as in the orders of the BIFR, we do not find any ground to disturb the said finding. Rightly, the Revenue had not raised any question of law on this. Even though on the aspect of jurisdiction, the Revenue succeeds, yet, the further question on the merits being a pure question of fact and rightly not raised, we do not find, any useful purpose would be achieved in setting aside the order of the Tribunal and further remanding the matter. In the circumstances, except for holding that the Revenue is justified in its plea in invoking jurisdiction under Section 263 of the Act, we do not think, the order calls for any interference to remand the matter. Advancing of funds by the assessee into the sister concern was in terms of the BIFR's order. That being the case, no useful purpose would be served by again directing a remand on the merits of the claim of the assessee.
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