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TMI Blog2015 (4) TMI 1174X X X X Extracts X X X X X X X X Extracts X X X X ..... see in this very appeal, by the order of the Division Bench [2015 (2) TMI 1233 - PUNJAB AND HARYANA HIGH COURT] as held that as the assessee has proved business expediency the advance is not covered by Section 2(22)(e) of the Act. Disallowance u/s 40A(2)(b) - Held that:- The second question raised is not a substantial question of law. It is purely a question of fact. The Commissioner of Income Tax ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... Chief Justice (Oral): The appellant has raised the following questions of law: "(i) Whether on the facts and circumstances of the case, the Hon'ble ITAT was justified in law, in deleting the addition of ₹ 1,25,00,000/- made u/s 2(22)(e) of the Income Tax Act, 1961 which was partly confirmed by the CIT(A) to the tune of ₹ 20,42,725/-. (ii) Whether on the facts and circumstances o ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 2015. 3. The second question raised is not a substantial question of law. It is purely a question of fact. The Commissioner of Income Tax (Appeals) and the Income Tax Appellate Tribunal rightly held that the mere fact that the assessee obtained loans @ 12% per annum does not belie the assessee's contention that the loans are from the family, which are at 15% per annum. It was a question of a ..... X X X X Extracts X X X X X X X X Extracts X X X X
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