2001 (12) TMI 7

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..... ake into consideration the relevant facts and based its decision on irrelevant factors not germane to the purpose of passing the said order. - we are, therefore, of the opinion that no question of law far less any substantial question of law arises for consideration in this appeal. We are further of the view that the learned Tribunal while passing the said order dated September 25, 2001, under sec .....

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..... ount. To us it appears that the, findings recorded by the Commissioner of Income-tax as also the Income-tax Appellate Tribunal are pure findings of fact. Appreciation of evidence does not fall within the realm of this court's jurisdiction under section 260A of the Income-tax Act. The Income-tax Appellate Tribunal had on earlier occasion remitted the matter for reassessment. The Commissioner of Inc .....

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..... ccount were not filed as the matter was very old. Letters were issued by the Assessing Officer to these seven parties for verification. Out of the seven parties, letters to three parties were received back with the postal remarks 'not known', another with the remark 'no claim' and one of the parties denied any business with the firm." Learned counsel for the appellant thereafter has taken us thro .....

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