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    <title>2016 (7) TMI 531 - PUNJAB AND HARYANA HIGH COURT</title>
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    <description>An appeal under Section 260A of the Income-tax Act, 1961 did not raise a substantial question of law where the Tribunal&#039;s deletion of additions rested on factual appreciation of evidence. The Tribunal found that the Revenue&#039;s relied agreement was not duly signed by the company, the alleged receipt of Rs. 70 lakhs was not proved by reliable evidence, and the material was only presumptive; it also held that the commission addition could not survive once the underlying transaction had already been consistently dealt with and the factual basis for the addition had failed. The HC treated these conclusions as findings of fact and declined to interfere, leaving the Tribunal&#039;s deletions undisturbed.</description>
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      <description>An appeal under Section 260A of the Income-tax Act, 1961 did not raise a substantial question of law where the Tribunal&#039;s deletion of additions rested on factual appreciation of evidence. The Tribunal found that the Revenue&#039;s relied agreement was not duly signed by the company, the alleged receipt of Rs. 70 lakhs was not proved by reliable evidence, and the material was only presumptive; it also held that the commission addition could not survive once the underlying transaction had already been consistently dealt with and the factual basis for the addition had failed. The HC treated these conclusions as findings of fact and declined to interfere, leaving the Tribunal&#039;s deletions undisturbed.</description>
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