HAFIZ MOHAMMED Vs. ASSISTANT COMMISSIONER

JUDGEMENT

(1.) THIS appeal has been filed by the assessee against the impugned judgment of the Appellate Tribunal annexure -1.

(2.) BY annexure 1 the learned Tribunal had decided two appeals being Appeals Nos. 663 and 664. Appeal No. 663 related to the assessment year 1989 -90, while Appeal No. 664 related to the assessment year 1990 -91. In the present appeal the findings arrived at by the learned Tribunal while deciding Appeal No. 663 only have been assailed, and that also with respect to ground No. 1 only whereby the Tribunal allowed the appeal of the Revenue, and set aside the deletion of the amount purportedly on account of unexplained investment on the plot bearing No. 27D.

(3.) ON the other hand, learned Counsel for the Revenue submits that the finding recorded is a pure finding of fact, and does not involve any substantial question of law. In our view, the present appeal does involve the substantial question of law being: