2019 (5) TMI 201

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....assessee against the order passed by the High Court by which a bunch of appeals, some filed by the assessee and some filed by the Commissioner of Income Tax (Revenue) under Section 260A of the Income Tax Act, 1961(hereinafter referred to as "the Act") were disposed of. 4. So far as the appeals filed by the assessee were concerned, they were dismissed and so far as the appeals filed by the Commissioner of Income Tax were concerned, they were allowed. The assessee has felt aggrieved and has filed these appeals by way of special leave in this Court. 5. We do not consider it necessary to set out the facts of the case in detail in the light of the order that we are passing for the disposal of these appeals. 6. Heard Ms. Anitha Shenai, l....

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....tion between the questions proposed by the appellant for admission of the appeal and the questions framed by the Court. 23. The questions, which are proposed by the appellant, fall under Section 260A (2) (c) of the Act whereas the questions framed by the High Court fall under Section 260A (3) of the Act. The appeal is heard on merits only on the questions framed by the High Court under subsection (3) of Section 260A of the Act as provided under Section 260A (4) of the Act. In other words, the appeal is heard only on the questions framed by the Court. 24. Third, if the High Court was of the view that the appeal did not involve any substantial question of law, it should have recorded a categorical finding to that effect sayi....