1987 (6) TMI 13

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....The petitioner is the same person in both the O.Ps. He is an assessee to income-tax. The respondent in both these O.Ps. is the Commissioner of Income-tax. The petitioner prays that the following two questions of law may be directed to be referred by the Appellate Tribunal for the decision of this court. The questions of law formulated by the petitioner-assessee in both the O.Ps. are as follows : ....

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....sferred to the trustees, no trust had, in fact, been created. This finding has been arrived at by the Appellate Tribunal. It is not questioned. If that be so, the contribution of Rs.1 lakh or transfer of Rs.1 lakh to the trustees even before the trust has been created cannot be said to be a proper or allowable expenditure. On this short ground, the common question No. (i) in both the O.Ps. does no....