Held, dismissing the appeal of the revenue the Court held  that the Tribunal had duly analysed the facts before it had reduced the disallowance to six per cent. from 12.5 per cent. as restricted by the Commissioner (Appeals) and therefore, no interference was called for in its findings and order. In the judgment in PCIT v. Surya Impex (2023) 451 ITR 395 (Guj)(HC) wherein, on the issue of accommodation entries provided by the same group alleged to have provided accommodation entry to the assessee, the court had held in favour of the assessee. The questions of law involved were of similar nature and were in the context of similar facts involving the same group. No other question of law arose. (AY.2007-08)