1.      HOTLINE INTERNATIONAL P.LTD (Delhi High Court)

Since the order of the Tribunal is based on the concession and therefore there was no need to consider the aforesaid aspect, we are of the opinion that it would be proper for the petitioner to move application under Section 254 before the Income Tax Appellate Tribunal.

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2.      SUN RIDER INDIA P.LTD (Delhi High Court)

These two persons even filed their confirmation with all the supporting evidence to justify the claims of expenditure and genuineness of transaction. We are, therefore, of the opinion that these are the findings of fact recorded on the basis of evidence produced before the Authority below.

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3.      P.S.BEDI & COI (Delhi High Court)

In its detailed order, the learned Income Tax Appellate Tribunal has discussed the evidence produced by the assessee on the basis of which it returned a finding of fact that the commission paid by the assessee to its agent was genuine.

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