PCIT v. Gahoi Buildwell (P.) Ltd. (2022) 447 ITR 315 (Delhi)(HC)

S. 260A : Appeal-High Court-Business expenditure-Order of Tribunal deleting disallowances based on appreciation of facts-Cannot be disturbed unless order is illegal or perverse. [S. 254(1)]

Dismissing the appeal of the Revenue the Court held that the Tribunal had considered all the issues in depth. The findings given by the Tribunal were based on appreciation of facts. The issues raised by the Department did not involve any substantial question of law and need not be interfered with in appeal under section 260A. The Tribunal had given separate findings on all the issues for all the three assessment years 2007-08, 2008-09 and 2009-10 and there was no perversity in its orders passed under section 254. No question of law arose. (AY.2007-08 to 2009-10)