2004 (3) TMI 31

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....Gupta for the appellant. Heard on admission. This appeal under section 260A of the Income-tax Act, 1961 (hereinafter referred to as "the Act"), is at the instance of the Revenue against an order passed by the Income-tax Appellate Tribunal in I.T.A. No. 16/Ind of 1997 for the assessment year 1993-94 decided on May 23, 2003. The appeal before the Tribunal was also at the instance of the appellant....

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.... of the agents was also established. It has also been found that the commission was paid exclusively for business purposes only. All these are findings of fact and no substantial question of law, as is required to be formulated for deciding the appeal, arises in the same. The Tribunal has also placed reliance on a judgment of the Delhi High Court reported in CIT v. Electric Construction Equipme....