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2007 (9) TMI 267 - HC - Income TaxWe have considered each of the issues asked for reference; however, taking note of the fact that all the issues are based on facts and essentially, require re-appreciation which is not permissible for reference to this court. It is not a case where either material available on record was ignored or the Tribunal recorded its finding without considering the material, rather perusal of the order reveals that each and every material was properly considered to arrive at the finding - In view of the facts discussed above, we are not in agreement with the Revenue to accept this reference application, so as to call for reference for its answer under the provisions of section 256(2) of the Income-tax Act. Hence, this reference application preferred by the Revenue is not accepted; the same is hereby dismissed.
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