9911796707
TMI Blog2006 (12) TMI 95X X X X Extracts X X X X X X X X Extracts X X X X ..... reinafter referred to as "the Act"), the Commissioner of Income-tax, Meerut, seeks to direct the Income-tax Appellate Tribunal, Delhi (hereinafter referred to as "the Tribunal"), to draw a statement of the case and refer the following question of law for the opinion of this court: "Whether, on the facts and circumstances of the case, the learned Income-tax Appellate Tribunal was justified in dele ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ssee was having business relations. It may be mentioned here that the respondent-assessee had shown a sum of Rs. 5,84,000 as income from dividend in respect of the investment made by it in the shares of other companies and the respondent-assessee had paid a sum of Rs. 4,65,539 towards interest to the Hongkong and Sanghai Banking Corporation. The assessing authority had disallowed the claim of the ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... tion and, therefore, it cannot be said that the term loan had not been utilised. Moreover, we find that in the memorandum and articles of association of the respondent-assessee, investment in shares was specified and the respondent-assessee under law could be treated to be doing business of investment in shares, therefore, the interest paid by it to the Hongkong and Shanghai Banking Corporation is ..... X X X X Extracts X X X X X X X X Extracts X X X X
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