IN THE HIGH COURT OF BOMBAY AT GOA TAX APPEAL NO. 19 OF 2010 THE COMMISSIONER OF INCOME TAX ... Appellant Versus M/S. SONATAPES PRIVATE LIMITED ... Respondent Ms. Asha Dessai, Advocate for the Appellant. Mr. Parag Rao, Advocate for the Respondent. Coram:- S. J. VAZIFDAR & U. D. SALVI, JJ. Date:- 19th April, 2010 P.C. There is no question of law that arises in this case. 2. The two shareholders are husband and wife. Each has a beneficial shareholding of less than 20 per cent. Whether either of them has a beneficial interest to the entire shareholding is a pure question of fact. 3. The Appeal is dismissed. S. J. VAZIFDAR, J. U. D. SALVI, J. arp/*