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TMI Blog1980 (8) TMI 26X X X X Extracts X X X X X X X X Extracts X X X X ..... 6 arise between the same parties and since common questions of law and fact are involved therein, they are being disposed of by one judgment. The assessee is a private limited company carrying on the business of manufacture of pistons at Amritsar. Earlier its status was that of partnership firm and it was converted into a private limited company with effect from April 1, 1968. The dispute relates ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 250 per month under s. 40(c) of the I.T. Act, 1961 (hereinafter called "the Act"). The assessee filed an appeal against the order passed by the ITO which was dismissed. Second appeal was taken to the Income-tax Appellate Tribunal which fixed the salary of Sh. Sadhu Singh at Rs. 2,500 per month along with annual increments at the rate of Rs. 200. The application filed by the assessee before the App ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... g director of the company ? " After hearing the learned counsel for the parties, we are of the view that there is no merit in these petitions. The Tribunal took notice of all the relevent circumstances, i.e., the education and technical experience of Sh. Sadhu Singh, the part played by him in promoting the business of the company, and the overall business of the assessee. On this basis, it came t ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... one of fact. The Tribunal was, therefore, justified in declining to make a reference to us. The learned counsel for the assessee had, however, placed reliance on some authorities to which a reference may be made now. In CIT v. Walchand and Co. Private Ltd. [1967] 65 ITR 381 (SC), the court was concerned with the question whether an expenditure was wholly and exclusively laid out for the purpose o ..... X X X X Extracts X X X X X X X X Extracts X X X X
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