IN THE HIGH COURT OF JUDICATURE AT PATNA MA No.347 of 2006 COMMISSIONER OF INCOME TAX, MUZAFFARPUR..APPELLANT Versus M/S MASSENA BEEJ PVT.LTD.,JAIPUR ROAD, AMASTIPUR……………………………………… RESPONDENT ----------- 5 27-1-2011 Heard learned counsel for the appellant and perused the order under appeal passed by the Income Tax Appellate Tribunal, Patna Bench, Patna dated 28th April,2006 in I.T. (SS ) A N0. 86/PAT/2005. 2. Learned counsel for the appellant argued that the grounds no. 2 and 3 constitute substantial questions for the purpose of admission of appeal preferred under section 260 A of the Income Tax Act 1961. 3. Both the grounds, in our considered view, raise issues of fact which are concluded by the judgment under appeal passed by the learned Tribunal. There being no substantial question of law arising for our determination from the judgment and order under appeal, this appeal is dismissed. Naresh ( Shiva Kirti Singh, J.) ( Dr. Ravi Ranjan,J)