https://www.taxtmi.com/caselaws?id=6353 The Supreme Court held that questions 1 to 3 raised no referable question of law because the controversy was essentially factual and the Tribunal had considered the relevant material, including the agency arrangement, evidence of alleged sub-agents, and surrounding correspondence. The Court reaffirmed that a Tribunal must take account of all material evidence, but found that requirement satisfied on the record, and that isolated items relied on by the assessees did not undermine the factual conclusions. The High Court was therefore right to decline a reference on those questions, and the factual findings against the assessee companies were upheld. en-us Fri, 24 Sep 1971 00:00:00 +0530 Thu, 04 Dec 2008 00:00:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=6353 The Supreme Court held that questions 1 to 3 raised no referable question of law because the controversy was essentially factual and the Tribunal had considered the relevant material, including the agency arrangement, evidence of alleged sub-agents, and surrounding correspondence. The Court reaffirmed that a Tribunal must take account of all material evidence, but found that requirement satisfied on the record, and that isolated items relied on by the assessees did not undermine the factual conclusions. The High Court was therefore right to decline a reference on those questions, and the factual findings against the assessee companies were upheld. Case-Laws Income Tax Fri, 24 Sep 1971 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=6353