TMI Blog1987 (10) TMI 35X X X X Extracts X X X X X X X X Extracts X X X X ..... statement of the case on the following questions : " (1) Whether, on the facts and in the circumstances of the case, the Income-tax Appellate Tribunal was correct in law in deleting an addition of Rs. 41,500 in respect of charity included in the purchase price of cotton by payment of Rs. 2 per bale of cotton purchased ? (2) Whether, on the facts and in the circumstances of the case, the income ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... at the rate of 10% on the debit balances outstanding in the account of three dealers of the assessee-company. Detailed facts in this regard have been stated by the Commissioner of Income-tax (Appeals) in his order dated April 4, 1977, in para 70. The view of the Income-tax Officer was that the assessee gave credit facility to the three dealers for some extra commercial consideration and that was ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... isation would have been less or both." Relying on these findings, the Income-tax Appellate Tribunal came to the conclusion that the Income-tax Officer was not right in estimating the interest income notionally. These are purely findings of fact and no question of law arises therefrom. For the above reasons, we do not agree with the Revenue that question No. 2 is a question of law. The applicat ..... X X X X Extracts X X X X X X X X Extracts X X X X
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