Revisional jurisdiction limited to questions of law, preventing interference with factual findings on forest land and taxable standing trees

Revisional jurisdiction under section 11 of the U.P. Trade Tax Act is confined to questions of law and does not permit reappreciation of evidence or interference with pure findings of fact. The Tribunal had categorically found that the land was forest within the Indian Forest Act and that the standing trees sold by auction were goods liable to trade tax. Because the dispute turned on factual determination of the character of the land and trees, the revisional court could not interfere, and the Tribunal's findings were left undisturbed.

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Issues: Whether the revisional court could interfere with the Tribunal's finding that the land in question was a forest and that the standing trees sold by auction were goods liable to trade tax.

Analysis: The Tribunal recorded a categorical finding that the land fell within the definition of forest under the Indian Forest Act and that the standing trees constituted goods under the Trade Tax Act. The revisional jurisdiction under section 11 of the U.P. Trade Tax Act is confined to questions of law and does not permit reappreciation of evidence or interference with pure findings of fact. The dispute raised before the court was therefore one of factual determination, including the characterization of the land and the taxable nature of the trees sold.

Conclusion: The Tribunal's findings were not open to interference in revision and the tax liability was upheld.

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