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Issues: Whether, on the facts and circumstances of the case, the Tribunal was right in holding that the assessee's salary was paid by the foreign company and not by FACT.
Analysis: The question was treated as a pure question of fact. The finding recorded by the Tribunal was not challenged on the ground of perversity, and therefore it was accepted as correct.
Conclusion: The answer was in the affirmative and in favour of the assessee.