1987 (9) TMI 7

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..... No. 223 of 1984 relates to the company and the other two to a firm. The question sought to be raised by the Department is whether the Tribunal was right in holding that the firm was a genuine firm and that the income returned by the firm was assessable in its hands and had to be excluded from the assessment of the company. This obviously is a question of fact (vide Ratanchand Darbarilal v. CIT [1 .....

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..... r services and that there were also stranger partners in the firm who are not associated with the company or its directors in any way. We also find that the Commissioner of Income-tax (Appeals) had given a clear finding that the net income of the firm during all the years when it was in existence was a paltry sum and that having regard to this consideration also, it was not likely that the persons .....

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