The Appellate Tribunal is final fact finding authority

The Appellate Tribunal is final fact finding authority. Its finding on facts is final and no appeal lies to the
Honble High Court, except on substantial question of law. The powers are very wide but there is no power of
enhancement. All questions, whether of law or a fact which relate to the assessment of an assessee may be raised
before the Tribunal. The powers include the power to annul an assessment order or set aside or remand. The
powers have been expressed in the widest possible terms. It has power to grant stay and rectify its own order,
with no right to review.
Question of law and question of fact
Question of fact is a question which must be answered by reference to facts and evidence, and inferences arising
from those facts. Such a question is distinct from a question of law, which must be answered by applying
relevant legal principles. The answer to a question of fact is usually dependent on particular circumstances or
factual situations.
Question of law is a question which must be answered by applying relevant legal principles, by an interpretation
of the law. Such a question is distinct from a question of fact, which must be answered by reference to facts and
evidence, and inferences arising from those facts. Answers to questions of law are generally expressed in terms
of broad legal principles, and are capable of being applied to many situations, rather than being dependent on
particular circumstances or factual situations.