9911796707
TMI Blog2014 (4) TMI 1016X X X X Extracts X X X X X X X X Extracts X X X X ..... mpt to re-appreciate and reappraise the factual materials - After the scrutiny and assessment of all materials placed on record, the facts before the Commissioner did not justify arriving at the requisite satisfaction - it has scrutinized the claims and found that substantial part are covered by the earlier orders of the Tribunal - The truck hire charges claimed have not been found to be worth reo ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... is submitted that the question of law no.1 would arise for determination and consideration in this Appeal. That pertains to invoking the powers conferred by section 263 of the Income Tax Act. It is submitted that the Tribunal has erred in holding that these powers could not have been invoked in the present case. It is submitted that the facts justified invoking of that power. The Commissioner was ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... to modify the order under section 145(3), after treating the interest income of Rs.1,47,83,785/- as 'income from other sources'. He directed that the claim of remuneration to the partners be computed after reworking the booked profit excluding the aforesaid interest income. Further directions were also issued with regard to a payment of truck hire charges amounting to Rs.41,07,800/. It is ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... the earlier order of the Tribunal, and therefore, all the more, this was not a case where the Commissioner was justified in invoking section 263 of the Act. 4. We are of the view that the questions as posed before us cannot be termed as substantial questions of law. It is clearly an attempt to reappreciate and reappraise the factual materials. After the scrutiny and assessment of all materials ..... X X X X Extracts X X X X X X X X Extracts X X X X
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