Issue of perversity of findings could by itself come within the ambit of a substantial question of law

In a recent ruling, in the matter of Chevoit Company Ltd. Vs. CIT (ITA No. 137 of 2001) (Calcutta HC – Special Jurisdiction {Income-tax}) the Calcutta High Court (HC) held that assessment by lower authorities without reference to the evidence produced by the assessee must be held to be perverse, and that the perversity of the finding itself becomes a substantial question of law. Facts :- The assessee is engaged in the business of manufacturing and has a factory in Noida. During the course of assessment proceedings, the Assessing Officer disallowed a part of welfare, power and fuel and la...