https://www.taxtmi.com/caselaws?id=49664 Tribunal findings that intermediary sales were sham and that profits shown in intermediaries accrued to the assessee are factual inferences from primary evidence and therefore not referable as questions of law under section 66(1) of the Income-tax Act, 1922; the characterisation of intermediaries as benamidars was treated as factual or mixed depending on whether legal tests of beneficial ownership applied, and here rested on evidentiary findings of fictitious sales; and the statutory application of provisions governing branch sales was already settled while the Tribunal's 85:15 apportionment of profits is an allocation of fact, not a pure legal question, so no reference is warranted. en-us Wed, 26 Sep 1956 00:00:00 +0530 Fri, 09 Jan 2015 15:59:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=49664 Tribunal findings that intermediary sales were sham and that profits shown in intermediaries accrued to the assessee are factual inferences from primary evidence and therefore not referable as questions of law under section 66(1) of the Income-tax Act, 1922; the characterisation of intermediaries as benamidars was treated as factual or mixed depending on whether legal tests of beneficial ownership applied, and here rested on evidentiary findings of fictitious sales; and the statutory application of provisions governing branch sales was already settled while the Tribunal's 85:15 apportionment of profits is an allocation of fact, not a pure legal question, so no reference is warranted. Case-Laws Income Tax Wed, 26 Sep 1956 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=49664