HOMI JEHANGIR GHEESTA vs THE COMMISSIONER OF INCOME-TAX, BOMBAY

The Supreme Court held that under Section 66(2) of the Indian Income-tax Act, 1922, no question of law arose from the Appellate Tribunal's order regarding the assessment of undisclosed income. The Court affirmed the Tribunal's decision, stating that the rejection of the appellant's explanations did not establish the nature of the receipt as income, but the inference drawn by the assessing authorities was a matter of fact. The appeal was dismissed, upholding the High Court's summary dismissal of the application for reference.