/ 1 / IN THE HIGH COURT OF JUDICATURE AT BOMBAY ORDINARY ORIGINAL CIVIL JURISDICTION INCOME TAX APPEAL NO.1113 OF 2004 The Commissioner of Income Tax-3 ...Appellant Vs. M/s. Reliance Commercial Corporation ...Respondents ----- Mr.Vimal Gupta for Appellant Mr.J.D. Mistry a/w. Mr.Raj Darak for Respondent CORAM: SWATANTER KUMAR, C.J. & V.M. KANADE J. DATED JULY 3, 2008 P.C. 1. It is not in dispute that the questions raised in this appeal are the questions of facts and not the questions of law and they are merely based upon the appreciation of evidence. In any case it is commonly conceded that even this aspect is squarely held against the Department repeatedly. Therefore, there is no substantial questions of law involved in this appeal. Hence, the appeal is dismissed. CHIEF JUSTICE V.M. KANADE J. / 2 /