COMMISSIONER OF INCOME-TAX Vs. UNITED BREWERIES LIMITED

JUDGEMENT

(1.) REVENUE aggrieved by the order of the Tribunal dtd 4 -11 -1999 is before us. The following questions of law are framed;

(2.) THE facts of the case are as under;

(3.) IN so far as corporate guarantee is concerned, he has referred to us the order of the tribunal and also the order of the assessing authority. He would say that the tribunal has committed a serious error in granting this allowance in favour if the assessee. He would say that allowance of the said amount is unsustainable in law. He would say that there is every chance of the assessee recovering the said guarantee amount, in which event the department would be put to loss in terms of his submission. Similarly he would argue that consideration of legal expenses by the tribunal also require our interference.