HVN IN THE HIGH COURT OF JUDICATURE AT BOMBAY IN THE HIGH COURT OF JUDICATURE AT BOMBAY IN THE HIGH COURT OF JUDICATURE AT BOMBAY ORDINARY ORIGINAL CIVIL JURISDICTION ORDINARY ORIGINAL CIVIL JURISDICTION ORDINARY ORIGINAL CIVIL JURISDICTION INCOME TAX APPEAL (L) NO. 398 OF OF OF 2006 WITH NOTICE OF MOTION NO. 905 OF 2006 The Commissioner of Income Tax ... Appellant Vs. L/H Late Dipchand Shah ... Respondent Mr. R. Ashokan for the Appellant. Mr.Y.R. Dube for the Respondent. CORAM: F.I. CORAM: F.I. CORAM: F.I. REBELLO REBELLO REBELLO & R.S. MOHITE, JJ. R.S. MOHITE, JJ. R.S. MOHITE, JJ. DATED: MARCH 17, 2008 DATED: MARCH 17, 2008 DATED: MARCH 17, 2008 P.C. P.C. P.C. . There is delay of 336 days in preferring the appeal. . We have considered the appeal on merits. We find that the Commissioner Appeals after considering the material on record, accepted that the statement of the Assessee was valid and further found that there was no material to make additions in the matter of payment of ‘Pagari’. The ITAT by detailed reasoning had confirmed the said findings. Since these are purely findings of fact, the question of law would not arise. Consequently motion along with appeal dismissed. (R.S. MOHITE, J.) (R.S. MOHITE, J.) (R.S. MOHITE, J.) (F.I.REBELLO, J.) (F.I.REBELLO, J.) (F.I.REBELLO, J.)