COMMISSIONER OF INCOME-TAX, PUNJAB vs INDIAN WOOLLEN TEXTILE MILLS

The Supreme Court held that under the Income Tax Act, 1922, specifically Sections 15C and 66(1)(2), the Tribunal is responsible for determining questions of fact, while the High Court's role is to advise on questions of law. The Court found that the Tribunal misdirected itself by ignoring essential evidence and relying on an unsupported assumption regarding the relationship between 'Eldee' and 'Castle'. Consequently, the High Court erred in refusing to compel the Tribunal to state the case for its opinion, as a question of law did arise from the Tribunal's order.