1982 (9) TMI 157

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....h it is stated that the assessee applied the ITO within time for the issue of challan for payment of fee for filing the appeal before the Appellate Tribunal but such a challan was received by him only in June, 1982 and that in the circumstances the delay was unavoidable. The correctness of this submission has not been satisfactorily controverted by the revenue. I am, therefore, satisfied that ther....

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....der. 4. In the further appeal before me, the ld. Counsel for the assessee vehemently urged the ITO as well as the AAC did not dispute the factum of the payment of salary to the aforesaid two persons. He pointed out that the ITO did not disallow the claim on the ground that no services were rendered by them and that the AAC had erred in holding that the members aforesaid did not render any servi....