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The High Court of Gujarat dismissed the Commissioner of Income-tax's application as the Tribunal correctly found that no transfer of profits had occurred to another company. The Tribunal concluded that the assessee remained the rightful owner of the profits and the Income-tax Officer had not erred in allowing the claim. The Tribunal's findings were based on facts, and no question of law arose. The application was dismissed, and the rule was discharged with no order as to costs.
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