Court upholds disallowance of commission & stock valuation method change. No question of law.

The High Court upheld the decisions of lower authorities regarding the disallowance of commission paid by the assessee and the change in the method of valuation of closing stock. The court found the Tribunal's findings on both issues to be factual and dismissed the application, stating there was no question of law to refer.

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Issues:
1. Disallowance of commission paid by the assessee.
2. Change in the method of valuation of closing stock by the assessee.

Analysis:
1. The Commissioner of Income-tax disallowed a portion of the commission paid by the assessee, stating lack of proof of services rendered. The Commissioner of Income-tax (Appeals) overturned this decision, citing previous orders and voluminous correspondence as evidence. The Income-tax Appellate Tribunal upheld the decision based on lack of "contra material" and dismissed the Revenue's appeal. The High Court, in previous orders for similar assessment years, upheld the Tribunal's findings as factual, leading to the rejection of the application for reference on question No. 1.

2. The assessee changed its method of valuing closing stock for the assessment year 1978-79. The Income-tax Officer did not accept this change initially. However, the Commissioner of Income-tax (Appeals) found the change justified based on uniformity and commercial principles. The Tribunal upheld this decision, and the Revenue's subsequent application was rejected. The High Court deemed the Tribunal's decision on the valuation method change as factual, finding no question of law to refer question No. 2.

In conclusion, the High Court dismissed the application, maintaining the decisions of the lower authorities on both issues. The court found the Tribunal's findings on both matters to be factual and not warranting a reference on questions of law.

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