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2007 (6) TMI 192

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....se 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 Siva, a sister concern towards packing and f....

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....998, 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 director of the sister concern and the partners o....

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....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 recipient to justify terming the payment as a business expen....