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    <title>1967 (5) TMI 11 - Supreme Court</title>
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    <description>In an income-tax reference, the High Court could not reappraise evidence or replace the Tribunal&#039;s factual finding that termination of the managing agency was not bona fide and was driven by an improper purpose; that finding had to be accepted, with the legal test applied only to those facts. Where, however, the Tribunal&#039;s finding on commercial expediency and the business character of the compensation payment was incomplete or unsatisfactory, the proper course was remand for a clear factual finding after considering all relevant material. The High Court&#039;s answer was therefore set aside and the deductibility issue remained open pending fresh determination by the Tribunal.</description>
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    <pubDate>Thu, 04 May 1967 00:00:00 +0530</pubDate>
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      <title>1967 (5) TMI 11 - Supreme Court</title>
      <link>https://www.taxtmi.com/caselaws?id=5066</link>
      <description>In an income-tax reference, the High Court could not reappraise evidence or replace the Tribunal&#039;s factual finding that termination of the managing agency was not bona fide and was driven by an improper purpose; that finding had to be accepted, with the legal test applied only to those facts. Where, however, the Tribunal&#039;s finding on commercial expediency and the business character of the compensation payment was incomplete or unsatisfactory, the proper course was remand for a clear factual finding after considering all relevant material. The High Court&#039;s answer was therefore set aside and the deductibility issue remained open pending fresh determination by the Tribunal.</description>
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      <pubDate>Thu, 04 May 1967 00:00:00 +0530</pubDate>
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