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Issues:
1. Whether questions raised by the assessee for opinion are questions of law or questions of fact. 2. Validity of notice under section 212(3A) of the Income Tax Act as the basis for determining estimated income. 3. Compliance with principles of natural justice and provisions of sections 142, 143, and 69 of the Income Tax Act before framing assessment. 4. Issuance of notice to the assessee-firm on the day of assessment. Detailed Analysis: 1. The assessee-firm approached the Tribunal seeking to refer questions to the court for opinion, contending they were questions of law. However, the court held that the questions were actually questions of fact, as there was material on record to determine the income and no violation of natural justice or compliance issues were raised during the assessment proceedings. 2. The contention regarding the validity of the notice under section 212(3A) as the basis for determining the estimated income at Rs. 75,000 was dismissed by the court. It was ruled that this issue was a question of fact, as the plea regarding the previous assessment status of the assessee was not raised before any authority previously, and the demand notice under section 212(3A) was considered relevant in estimating the income. 3. The court found that there was no material before the Tribunal to suggest non-compliance with natural justice principles or provisions of the Income Tax Act. The assessee failed to demonstrate any wrong inference in law by the Tribunal, and it was noted that no arguments were presented regarding violation of natural justice during the assessment proceedings. 4. The court addressed the issue of whether a notice was issued to the assessee-firm on the day of assessment. The counsel for the assessee could not provide any evidence to suggest that no notice was issued on the specified date. As no arguments were presented on this matter, the court found no merit in this aspect of the petition and dismissed it without any costs awarded.
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