K.J. IN THE HIGH COURT OF JUDICATURE AT BOMBAY ORDINARY ORIGINAL CIVIL JURISDICTION INCOME TAX APPEAL NO.901 OF 2007 The CIT Central-III ..Appellant Versus M/s.United Liner Agencies(Stevedores)..Respondent ---- Mr.B.M.Chatterji @ Mrs.P.P.Bhosale and Mr.P.S.Sahadevan for the appellant. Mr.P.R.Toprani with Usha I. Dalal for respondent. ---- Coram : F.I.Rebello & R.S.Mohite,JJ Coram : F.I.Rebello & R.S.Mohite,JJ Coram : F.I.Rebello & R.S.Mohite,JJ Date : 12.03.2008. PC 1. The Tribunal in the impugned order in paragraph-18 has held as under :- " It is therefore apparent that the reasons have been recorded without careful examination of the material gathered at the time of survey and any further inquiry thereafter. We therefore hold that initiation of proceedings under section 147 has been made based on the material, if any, that has no specific nexus with the assessment years under consideration befure us." 2. These are purely findings of fact. The question of law as framed would not arise and consequently, appeal dismissed. : 2 : (R.S.Mohite,J) (F.I.Rebello,J) (R.S.Mohite,J) (F.I.Rebello,J) (R.S.Mohite,J) (F.I.Rebello,J)