2007 (10) TMI 724 - HC - Income Tax

Summary

The Delhi High Court, through Judges Madan B. Lokur and Dr. S. Muralidhar, dismissed the appeal against the Income Tax Appellate Tribunal's order for assessment year 1997-98. The key issue was whether the assessee had commenced business in the relevant year. The Tribunal had earlier determined the commencement of business occurred in the last quarter of the financial year, disallowing pre-commencement expenditure deductions-a conclusion which became final. Subsequently, the assessing officer, Commissioner (Appeals), and Tribunal concurred that business commenced on 8-1-1997 upon acceptance of an import offer. The High Court found no perversity or substantial question of law in this factual finding and upheld the concurrent decisions, stating: "no substantial question of law arises for our consideration." The appeal was dismissed accordingly.