1991 (9) TMI 28

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....see is a partnership firm consisting of four partners. We are concerned with the assessment year 1973-74 for which the accounting period is Samvat year 2028. Four partners of the assessee-firm obtained loan of Rs. 10,000 each in their individual names from the Surat People's Co-operative Bank and the aggregate amount of Rs. 40,000 so borrowed by the partners was transferred on that very day to the....

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....er section 40(b). The assessee having failed in appeal before the Appellate Assistant Commissioner went in further appeal to the Tribunal. The Tribunal, following its earlier decisions, held So the effect that the partners of the assessee-firm had acted as intermediaries or a conduit pipe to obtain loan for the purpose of the business of the assessee-firm and that, in substance, the amount borrowe....

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....irm which had borrowed money for the purpose of its business through its four partners who had acted clearly as intermediaries or conduit pipe to obtain loan for and on behalf of the assessee-firm. The Tribunal has held that, in substance, the amount was borrowed by the assessee-firm for its business. There is no reason or justification to disturb this finding of fact recorded by the Tribunal. It,....

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....orporation and claimed it as deduction. The Income-tax Officer disallowed deduction of the interest paid to the Life Insurance Corporation and his decision was confirmed in appeal by the Appellate Assistant Commissioner. On further appeal, however, the Tribunal held that the disallowance was not justified. The Division Bench of the Punjab and Haryana High Court, while reversing the decision of the....