9911796707
TMI Blog1987 (5) TMI 6X X X X Extracts X X X X X X X X Extracts X X X X ..... d June 24, 1986, delivered in the above income-tax reference involves a substantial question of law and is a fit case for appeal to the Supreme Court. The question of law involved, said to be one of substance, is as follows: "Whether, on the facts and in the circumstances of the case, the Tribunal erred in holding that the excess payments of Rs. 6,34,484 and Rs. 42, 284 made on account of fluctu ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... vered by the Madras High Court in the case of CIT v. South India Viscose Ltd. [1979] 120 ITR 451, where the same point was involved, was rejected by the Supreme Court on August 2, 1983, as reported. The learned advocate for the applicant contended in reply that the question raised was one of some importance and was likely to recur in many international transactions. He also submitted that reject ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... olved in the said decision, section 43A of the Income-tax Act, 1961, was not promulgated. For the reasons as aforesaid, this application is allowed. Let a certificate be issued as prayed for. There will also be an order in terms of prayer (b). Let the order for issue of the certificate be drawn up separately. There will be no order as to costs. SHYAMAL KUMAR SEN J. -I agree. - - T ..... X X X X Extracts X X X X X X X X Extracts X X X X
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