Commissioner Of Income-Tax vs J.K. Beri

The Supreme Court held that the High Court erred in treating the findings of the Income-tax Appellate Tribunal as findings of fact, emphasizing that the Tribunal's conclusions were based on legal grounds under Section 147(a) of the Income-tax Act, 1961. The Court directed the Tribunal to refer the legal question regarding the reopening of assessment proceedings for the assessment year 1985-86 to the High Court for consideration. The appeal was allowed, and no costs were awarded.