IN IN IN THE HIGH COURT OF JUDICATURE AT BOMBAY THE HIGH COURT OF JUDICATURE AT BOMBAY THE HIGH COURT OF JUDICATURE AT BOMBAY ORDINARY ORDINARY ORDINARY ORIGINAL CIVIL JURISDICTION ORIGINAL CIVIL JURISDICTION ORIGINAL CIVIL JURISDICTION INCOME INCOME INCOME TAX APPEAL (LODG.) NO.869 OF 2006 TAX APPEAL (LODG.) NO.869 OF 2006 TAX APPEAL (LODG.) NO.869 OF 2006 The Commissioner of Income- ... ... Appellant Tax, Mumbai. Vs. M/s Saurashtra Ball Pen ... ... Respondents Pvt. Ltd., Mumbai Mr. S.M. Shah with Mr. P.S. Sahadevan for Appellant. Mr. M.M. Vaidya for Respondents. CORAM CORAM CORAM : F.I. REBELLO & : F.I. REBELLO & : F.I. REBELLO & R.S. R.S. R.S. MOHITE, JJ. MOHITE, JJ. MOHITE, JJ. DATE DATE DATE : 19TH MARCH, 2008 : 19TH MARCH, 2008 : 19TH MARCH, 2008 P.C. P.C. P.C. : : :- . Appeal heard forthwith. 2) Admit on the questions of law as formulated in Para 6 of the Appeal Memo. Revenue has preferred an appeal against the order of the Tribunal which has confirmed the findings recorded by the Commissioner of Appeals. 3) From the perusal of the order of the Tribunal, we find that the Tribunal had relied on the order of Assessment Year 1986 - 1987 which was upheld by the Tribunal in I.T.A. No. 4951 of 1992. The Appeal Memo does not disclose whether any appeal was preferred against the said order. 2 4) In our opinion, these are purely findings of fact. The questions of law does not arise, more so as the Tribunal relied on the order of the Assessment Year 1986 - 1987. 5) In the light of that, no interference is called for. 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.)