1 IN THE HIGH COURT OF BOMBAY AT GOA TAX APPEAL NO. 22 OF 2008 The Commissioner of Income Tax. ... Appellant versus Dr. P. R. Hede. ... Respondent Mr. S. R. Rivonkar, Advocate for the Appellant. CORAM : SWATANTER KUMAR, C.J. & N. A. BRITTO, J. DATE : 18TH MARCH, 2008. P.C.:- We have heard the learned Counsel appearing for the Appellant. The Order of the Income Tax Appellate Tribunal, Panaji expresses a view by referring to certain Judgments of the Supreme Court. The conclusion arrived at in the impugned Order is primarily based upon appreciation of evidence. Even in the question framed in the Memorandum of Appeal by the Department it does not raise any question of law, much less a substantial question of law. There is no merit in this appeal. Dismissed. CHIEF JUSTICE JUDGE RD.