HC cannot dismiss Revenue’s appeal in limine holding that no substantial question of law involved

Pr. CIT Vs Nokia India Pvt. Ltd. (Supreme Court of India) Conclusion: High Court was not justified in dismissing the appeal on the ground that the appeal did not involve any substantial question of law as it had to decide validity of s. 148 notice, whether notice based on change of opinion, assessed reasons to believe and findings recorded by ITAT on merits whether was legally sustainable. Therefore, the matter was remanded back to High Court. Held: Assessee challenged the notice issued under section 148 contending inter alia that since the impugned notice was based on “change of the opi...