1981 (11) TMI 9

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..... nce is as follows : "Whether, on the facts and in the circumstances of the case, the assessee-firm was entitled to renewal of registration under section 184/186 for the two years under consideration ? " The assessee-firm was granted registration for the assessment year 1967-68. Thereafter, the continuation of registration was granted till 1971-72. The ITO refused to grant continuation of regis .....

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..... Tribunal. The Tribunal has pointed out that their statements disclosed full awareness of their relations with the assessee-firm's constitution and its assets and finances, and they could not be merely held to be name-lenders. It has further been pointed out that M/s. C. J. Patel Co. did not derive any pecuniary benefit through the constitution of the assessee firm and that it paid interest at 1 .....

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