1 ITXA4002.09.sxw IN THE HIGH COURT OF JUDICATURE AT BOMBAY ORDINARY ORIGINAL CIVIL JURISDICTION KJ INCOME TAX APPEAL NO.4002 OF 2009 Commissioner of Income Tax -2 )..Appellant Vs. M/s.Apple Finance Ltd., )..Respondents ---- Mr. Vimal Gupta for the appellant. Mr. Sanjiv M. Shah for the respondents. ---- CORAM : J. P .DEVADHAR & MRS.MRIDULA BHATKAR,JJ DATE : 10/1/2011. PC 1 The dispute in this appeal is whether the Tribunal was justified in holding that the dispute in question was a debatable issue and therefore, the Assessing officer was not justified in invoking jurisdiction under Section 154 of the Income Tax Act 1961. 2 ITXA4002.09.sxw 2 The reasons recorded by the Tribunal in paragraph-7 of its judgment clearly shows that the decision is based on finding of fact. Hence, no question of law arises out of the order of the Tribunal. Appeal is dismissed. (MRS.MRIDULA BHATKAR,J) (J.P.DEVADHAR,J)