2001 (8) TMI 75

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.... ARIJIT PASAYAT C. J. -Since the points at issue in all the three references are similar, we dispose of the same by this common judgment. At the instance of the assessee, the following questions have been referred for the opinion of this court under section 256(1) of the Income-tax Act, 1961 (in short "the Act"), by the Income-tax Appellate Tribunal, Delhi Bench-D (the "Tribunal" in short): ....

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...., 1976-77 and 1977-78. We may not go into the factual position in detail in view of the fact that the issue whether the assessee had business connections with Nittetsu Mining Consultants Co. Ltd. of Japan (as raised in the first question), is a question of fact. The Tribunal has relied on certain provisions in the agreement to arrive at that conclusion. Therefore, no question of law arises. So ....