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Deputy Commissioner Of Income Tax ... vs Sulabh International Social Se on 29 March, 2011

(Emphasis is added) It is evident on a plain reading of section 35G of the Act that an appeal shall lie to the High Court if it involves a substantial question of law. Identical issue came up for our consideration in Misc. Appeal No. 657 of 2010 (Deputy Commissioner of Income Tax, Circle- 1, Patna Vs. Sulabh International Social Service Organisation), preferred by the Revenue in terms of Section 260-A of the Income-tax Act, 1961. This court examined the provisions of Section 260-A of the Income-tax Act, and Section 100 of the Code of Civil Procedure, which are in Pari Materia with each other wherein it has been held that an appeal to this court shall lie only if substantial question of law arises for consideration. Adequacy of materials, or possibility of another view on facts, is no ground for the High Court to entertain a second appeal under section 100 C.P.C. High Court can on facts interfere only after it reaches the conclusion that, in view of the materials on record, no person duly instructed in law can reach that conclusion. In other words, it is not possible to reach 7 the conclusion as has been arrived at by the first appellate court. The meaning and content of the expression „substantial question of law‟ has been discussed in paragraph 9.1 of the judgment and is reproduced hereinbelow:
Patna High Court - Orders Cites 4 - Cited by 7 - S K Katriar - Full Document
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