The Commissioner Of Income Tax vs Usha Stud And Agriculatural Farms Pvt. ... on 3 March, 2005
It is not appropriate for this Court to travel into determination of questions which are primarily factual and are based upon evidence. Where the authorities had taken a concurrent view in regard to the factual matrix of the case, there would be hardly any scope for this Court to interfere in such order. The question in regard to the method of valuation adopted by the assessed, maintenance of accounts and other such ancillary questions have been treated to be questions of fact rather than questions of law. Reliance in this regard has correctly been placed by the Counsel appearing for the respondents upon the judgment of this Court in the case of Bishan Singh Didar Singh v. Commissioner of Income Tax [1999] 106 TAXMAN 78 (DELHI) where the Court held as under:-