2007 (6) TMI 192

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....y P. D. Dinakaran J.— The above tax case appeals are directed against the common order of the Income-tax Appellate Tribunal dated August 5, 2005, in I. T. A. Nos. 968 to 975/Mds/1999 for the assessment years 1986-87 to 1993-94, respectively. The Revenue is the appellant. The relevant assessment years are 1986-87 to 1993-94. The assessee claimed deduction on account of payment to one Balaji....

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.... the said assessment orders dated March 27, 1998, the assessee preferred appeals before the Commissioner of Income-tax (Appeals), who by common order dated February 26, 1999, found that the sister concern had rendered the services and therefore the commission paid by the assessee-firm to the sister concern ought to have been allowed, but, since there is close relationship between the managing dire....

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.... by the Revenue ? 2. Whether, on the facts and in the circumstances of the case, the Tribunal had any basis to hold that the amounts paid as commission to a sister concern were allowable as a business expenditure ? 3. Whether, on the facts and in the circumstances of the case, the Tribunal was right in not going into the facts of whether any service had been actually rendered by the recipien....