- (1.) This is an appeal against the order of the Income Tax Appellate Tribunal in respect of the assessment year 1991-92.
(2.) The assessee filed its return of income declaring an income of about Rs. 10.78 crores. The assessment was completed under section 143(3) of the Income Tax Act, 1961 (for short 'the Act'). The Assessing Officer made several additions. The Commissioner of Income Tax (Appeals) sustained the additions in some respects and deleted certain other additions. The Department and the assessee filed appeals before the Tribunal. The Tribunal by the impugned order allowed the assessee's appeal and dismissed the appeal filed by the revenue.
(3.) According to the appellant, the following substantial questions of law have arise in this appeal:- (i) Whether on the facts and in the circumstances of the case, the Income Tax Appellate Tribunal was right in law in holding the amount of Rs. 1,18,408/- spent on articles presented to dealers as an allowable business expenditure (ii) Whether on the facts and in the circumstances of the case, the Income Tax Appellate Tribunal was right in law in deleting expenses on foreign travel of Directors wives (iii) Whether on the facts and in the circumstances of the case, the ITAT was right in law in holding that interest from others and also from IDBI constitute profit of the business for the purpose of computing deduction under section 80HHC (iv) Whether on the facts and in the circumstances of the case, the Income Tax Appellate Tribunal was right in law in deleting the addition of Rs. 77,85,059/- made on account of advances of interest free loans to the associated concerns whereas the assessee company was paying huge interest on the borrowed (v) Whether on the facts and in the circumstances of the case, the Income Tax Appellate Tribunal was right in law in deleting the proportionate management expenses allocated against dividend income for purpose of computation of deduction u/s 80M (vi) Whether on the facts and in the circumstances of the case, the ITAT was right in law in confirming the order of the learned CIT(A) in deleting the addition of Rs. 8,79,145/- made on account of closing stock, spares, tools etc.;