TMI Blog1980 (10) TMI 5X X X X Extracts X X X X X X X X Extracts X X X X ..... t, 1961, hereinafter called " the Act ". The material facts giving rise to this application briefly areas follows: The applicant-assessee is a firm registered under the Act. For the assessment year 1971-72, the applicant claimed a deduction of Rs. 15,598 as an expenditure wholly and exclusively incurred for the purposes of earning profits. The contention of the applicant was that the aforesaid am ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... appeal, the Tribunal, after considering the entire material on record, dismissed the appeal and upheld the finding of the ITO that the alleged agreement of agency was a sham transaction. Aggrieved by the order passed by the Tribunal, the assessee submitted an application for making a reference, but that application was rejected. Hence, the assessee has submitted this application. Having heard lea ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ansaction and that no payment by way of commission was made to Anil Bhasin was based on the material on record. The Tribunal took into consideration the fact that Anil Bhasin was a young boy, who claimed to be regular student of the college daring the entire period in question. The Tribunal further noted that Anil Bhasin did not have any business experience and that though according to the agency ..... X X X X Extracts X X X X X X X X Extracts X X X X
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