1973 (2) TMI 36

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....of the Income-tax Appellate Tribunal has submitted the statement of the case. The assessee is a partnership firm. Up to the assessment year 1966-67, it was assessed in the status of a registered firm having 7 partners. During the previous year for the assessment year 1967-68, which is the assessment year in dispute, there was a change in the constitution of the firm and a fresh deed of partnershi....

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....ent was prepared. It was also stated that a deed of rectification was executed on January 23, 1968, by all the partners and was filed before the Income-tax Officer on February 12, 1968. This deed of rectification was before the Income-tax Officer when be passed the order under section 185 of the Act refusing to grant registration. It was also submitted before the Income-tax Appellate Tribunal that....

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.... as framed is not a question of law. Whether there was any typing error or whether the firm was genuine or not are questions of fact and the Tribunal's findings on these questions cannot be challenged by way of reference unless the findings are based on no material or are perverse. On the material before the Tribunal, it cannot be said that the findings are without any material nor can they be sai....