Commissioner Of Income-Tax vs S. Zoraster And Co. on 12 September, 1979
In Karmni Properties Ltd. v. C2T [1971] 82 ITR 547 (SC), their Lordships of the Supreme Court held that the High Court was not entitled to reassess the evidence on record. When it was required to give its opinion " on the facts and in the circumstances of the case ", it means the facts and circumstances as found by the Tribunal and not the facts and circumstances as may be found by the High Court. In the aforesaid case, their Lordships made the following observations in this regard (p. 553):