1 IN THE HIGH COURT OF JUDICATURE FOR RAJASTHAN AT JODHPUR -------------------------------------------------------- INCOME TAX APPEAL No. 26 of 2008 DULI CHAND JAIN V/S A.C.I.T.CIRCLE-I,JODHPUR Mr. ARUN BHANSALI, for the appellant / petitioner Mr. KK BISSA, for the respondent Date of Order : 3.3.2008 HON'BLE SHRI N P GUPTA,J. HON'BLE SHRI DEO NARAYAN THANVI,J. ORDER ----- Heard learned counsel for the appellant. Learned counsel tried to assail the addition of Rs. 50,000/- as made by the learned Tribunal by reversing the judgment of the learned Commissioner, Income Tax Appeals, and to substantiate the argument learned counsel read to us the statement of the assessee recorded under Section 132(4), and also read to us the findings recorded by the learned Commissioner (Appeals) in para 5.2. After going through the said findings of the Commissioner, so also the finding of the learned Tribunal recorded in para-3, and reading the statement, in our view, the question remains a pure finding of fact, and does not involve any question of law. 2 Learned counsel then argued on the aspect of levy of interest, and penalty, and pressed into service amendment made and the notification under Section 119(2)(a) on waiver/reduction of interest chargeable under Section 158BFA(1). It would suffice to say that in the list of sections, in respect of which such orders are passed, included Section 158-BFA by Finance Act of 2002 with effect from 1.6.2002, whereas the present case relates to the block period ending much earlier to it. Apart from the fact, that even the order of the Commissioner (Appeals) is also earlier to the date when the amendment came into effect. Thus, no benefit can be claimed by the appellant on that count. No other question was argued. The appeal thus does not involve any substantial question of law. The same is, therefore, dismissed. ( DEO NARAYAN THANVI ),J. ( N P GUPTA ),J. /Sushil/