1987 (3) TMI 11

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..... introduced in section 37(2A) with retrospective effect from 1976. In our opinion, the other questions are all questions of fact. So far as question No. 2 is concerned, both the Commissioner of Income-tax (Appeals) and the Tribunal have found that a part of the expenses incurred on V. H. Dalmia relating to M/s. Delton Properties Ltd. was met out of the monies provided by the foreign company and .....

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..... are concerned. But so far as question No. 1 is concerned, we direct the Tribunal to state a case and refer the following question of law for the decision of this court "Whether, on the facts and in the circumstances of the case, the Tribunal was justified in restricting the disallowance under the head 'Sales promotion expenses ' from Rs. 1,04,857 to 20,970 particularly in view of the Explanatio .....

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