2006 (12) TMI 95

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....6(2) of the Income-tax Act, 1961 (hereinafter referred to as "the Act"), the Commissioner of Income-tax, Meerut, seeks to direct the Income-tax Appellate Tribunal, Delhi (hereinafter referred to as "the Tribunal"), to draw a statement of the case and refer the following question of law for the opinion of this court: "Whether, on the facts and circumstances of the case, the learned Income-tax Ap....

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....tronic Ltd., with whom the respondent-assessee was having business relations. It may be mentioned here that the respondent-assessee had shown a sum of Rs. 5,84,000 as income from dividend in respect of the investment made by it in the shares of other companies and the respondent-assessee had paid a sum of Rs. 4,65,539 towards interest to the Hongkong and Sanghai Banking Corporation. The assessing ....

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....al accrual during the year under consideration and, therefore, it cannot be said that the term loan had not been utilised. Moreover, we find that in the memorandum and articles of association of the respondent-assessee, investment in shares was specified and the respondent-assessee under law could be treated to be doing business of investment in shares, therefore, the interest paid by it to the Ho....