1991 (5) TMI 20

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..... . Two questions have been proposed in this application. The controversy raised revolves around the question whether the Income-tax Appellate Tribunal, in law, could permit the assessee to raise the plea of jurisdiction for the first time before it which was not raised earlier either before the Assessing Officer or before the first appellate authority. Having heard learned counsel for the parties .....

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..... the notice under section 148 of the Act being without jurisdiction. By the two questions proposed in this application, the findings recorded by the Income-tax Appellate Tribunal on merits have not been challenged, the answer to the question being self-evident. In our opinion, no statable question of law arises on which the Tribunal should be required to submit a statement of the case to this cour .....

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