THOMAS K T Vs. COMMISSIONER OF WEALTH TAX

JUDGEMENT

(1.) THE assessee is before us. THE questions, according to the assessee, arising from the order of the Tribunal are :

(2.) FACTS relevant to decide the issue can briefly be stated thus : The assessee filed the appeals as if they are not barred by limitation. On the Department pointing out that the appeals were filed out of time, the assessee filed petitions to condone the delay in filing the appeals. But, at the same time, the assessee was trying to sustain his contention that the appeals are not barred by limitation. A reference in this connection to the following excerpt from annexure-A filed along with O. P. No. 1194 of 1990 is profitable :

(3.) THE findings of the Tribunal, under the circumstances, cannot be said to be perverse. If that be the position, the questions challenging the said findings cannot he said to be questions of law arising out of the order bf the Tribunal.