https://www.taxtmi.com/caselaws?id=464240 The dispute concerned whether payments to a Canadian associate for services warranted disallowance and whether any substantial question of law arose on appeal. The matter was treated as primarily factual because the core issue was whether services had in fact been received against the payments. Earlier appellate proceedings had already accepted the assessee's position, and the Commissioner (Appeals) followed that consistent reasoning. On the facts, the Tribunal found that some services were rendered and that the payments were justified at arm's length. No substantial question of law arose, and the Revenue's challenge failed. en-us Wed, 13 Jun 2018 00:00:00 +0530 Mon, 13 Oct 2025 19:00:12 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=464240 The dispute concerned whether payments to a Canadian associate for services warranted disallowance and whether any substantial question of law arose on appeal. The matter was treated as primarily factual because the core issue was whether services had in fact been received against the payments. Earlier appellate proceedings had already accepted the assessee's position, and the Commissioner (Appeals) followed that consistent reasoning. On the facts, the Tribunal found that some services were rendered and that the payments were justified at arm's length. No substantial question of law arose, and the Revenue's challenge failed. Case-Laws Income Tax Wed, 13 Jun 2018 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=464240