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1992 (9) TMI 40

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....ces of the ease, the Tribunal was correct in law in holding that the disallowance of Rs. 15,000 confirmed by the Commissioner of Income-tax (Appeals) in respect of payment made to Shri H. P. Aggarwal does not fall under the purview of section 80VV of the Income-tax Act, 1961, and thereby deleting the disallowance ? 2. (a) Whether, on the facts and in the circumstances of the case, the Tribunal ....

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....18 and of Rs. 58,169, respectively ? " In our opinion, the aforesaid questions Nos. 1, 2(a) and 3, on the facts of this case, cannot be regarded as questions of law. Regarding question No. 1, there is no finding of fact that the provisions of section 80VV of the Act were applicable. In order that the said provision applies, it must be found as a fact that expenditure was incurred by the assesse....