1964 (2) TMI 79 - SUPREME COURT

Decline to entertain the application to raise questions other than those raised by the certificate granted by the High Court, because the questions sought to be raised are questions of fact which were not canvassed at the appropriate stage before the taxing authorities and the machinery provided under the Act for determination of questions relating to liability to tax is attempted to be bypassed.

The constitutional question on which certificate was granted does not need consideration in any detail. Appeal dismissed.