2001 (8) TMI 75

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..... r, we dispose of the same by this common judgment. At the instance of the assessee, the following questions have been referred for the opinion of this court under section 256(1) of the Income-tax Act, 1961 (in short "the Act"), by the Income-tax Appellate Tribunal, Delhi Bench-D (the "Tribunal" in short): "1. Whether, on the facts and circumstances of the case, the Tribunal was right in law i .....

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..... that the issue whether the assessee had business connections with Nittetsu Mining Consultants Co. Ltd. of Japan (as raised in the first question), is a question of fact. The Tribunal has relied on certain provisions in the agreement to arrive at that conclusion. Therefore, no question of law arises. So far as the second issue is concerned it has to be noted that the actual assessment took place a .....

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