Statutory appeal limits: refusal to entertain a loss return was not an appealable order under section 30.

A right of appeal exists only where statute expressly confers it, and section 30 of the Indian Income-tax Act, 1922 permitted appeals only from specified orders such as assessment, computation of loss, determination of tax, or denial of liability. An Income-tax Officer's refusal to entertain a loss return, without applying his mind to the merits, assessing income, or computing loss, was treated as a non-appealable order because it did not fall within those statutory categories. A revision remedy could still be available, but no appeal lay under section 30.

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Issues: Whether an appeal lay under section 30 of the Indian Income-tax Act, 1922, against an order where the Income-tax Officer declined to entertain a loss return and did not compute the loss.

Analysis: The right of appeal is not inherent and exists only when conferred by statute. Section 30 confers appeal only against specified orders, namely assessment of income, computation of loss, determination of tax, or denial of liability. On the facts, the Income-tax Officer did not apply his mind to the merits, did not assess the income, and did not compute the loss; he merely treated the return as invalid. Such an order did not fall within any of the categories enumerated in section 30. A revision could be available, but not an appeal.

Conclusion: No appeal was competent under section 30, and the question was answered in the negative against the assessee.

Ratio Decidendi: An appeal lies only from an order expressly made appealable by the statute, and a refusal to entertain a return without assessment or computation of loss is not an appealable order under section 30 of the Indian Income-tax Act, 1922.

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