2015 (1) TMI 969

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..... Jayant Patel: 1. The present appeals are directed against the impugned orders passed by the Tribunal in the respective matters, whereby the Tribunal, for the reasons recorded in the orders, has allowed the appeals of the assessee and has dismissed the appeals of the Revenue. 2. We have heard Mr.M.R. Bhatt, learned Counsel appearing for the appellant. 3. As such the Tribunal, upon examination o .....

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..... ect, inasmuch as the Tribunal has not dealt with the factual aspect in detail to record the said conclusion by way of a final authority for finding of fact. He submitted that even if the agreements are not properly considered by the Tribunal, it would be a substantial question of law to be considered in the present appeals being under Section 260-A of the Act. He, therefore, submitted that the app .....

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..... paragraph 9 observed thus:-              "Further before us, Revenue could not controvert the findings of ld. CIT(A), nor has brought any contrary binding decision in its support. Revenue could not distinguish the facts in the case of Heramac Ltd.(supra) with that of Assessee. ..." 6. The aforesaid shows that the Tribunal was satisfied .....

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