(1.) In this appeal under section 260-A of the Income Tax Act, 1961, the appellant has raised three substantial questions of law in respect of the judgment and order of the learned Income Tax Appellate Tribunal, Agra Bench, Agra, dated 8th July, 2019. The substantial questions of law, as formulated by the appellant, read as follows :-
(2.) We notice from the papers before us that the learned Tribunal has proceeded to decide the appeal of the appellant, namely, Rakesh Kumar Gupta, upholding the order of the Commissioner of Income Tax (Appeals), being the first appellate authority who confirmed the assessment order dated 18th February, 2014, passed by the Income Tax Officer, Ward 2 (4), Mainpuri.
(3.) The questions of law, as set out hereinabove, in our view, are not substantial questions of law but are essentially factual in nature. The reasons for this conclusion will appear hereunder.