Substantial question of law restricts High Court appeals to the formulated legal issue while allowing limited exception arguments.

An appeal to the High Court from an Appellate Tribunal lies only when the High Court is satisfied a substantial question of law is involved. Such appeals must be filed by designated revenue officers or assessees within one hundred twenty days in a memorandum stating the substantial question, though the Court may admit delayed appeals for sufficient cause. The High Court formulates the question, hears the appeal on that question (while allowing respondents to contest its existence), may decide other substantial questions for reasons recorded, and must give a reasoned judgment; Assessing Officers must implement the judgment on certified copy.

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