JUDGMENT

D.K. Jain, J. —

1. Challenge in these two appeals, by special leave, is to the orders dated 21st December, 2001 and 19th February, 2002 whereby the High Court of Delhi dismissed : (i) the appeal filed by the appellant herein under Section 260-A of the Income Tax Act, 1961 (for short “the Act”) in I.T.A. No.202 of 2001, holding that the order of the Income Tax Appellate Tribunal, New Delhi (for short “the Tribunal”) did not give rise to any substantial question of law; and (ii) the review petition preferred by the appellant against order dated 21st December, 2001, holding that the petition was not maintainable.

2. Shorn of unnecessary details, the facts material for adjudication of the present appeals may be stated. These are :

The appellant (hereinafter referred to as “the assessee”) was a partner in a firm, named and styled as M/s Des Raj Tilak Raj, having its business at Delhi, with a branch at Calcutta. The said partnership firm was dissolved w.e.f. 1st April 1982. As per the dissolution deed, the assessee took over the business of the Calcutta branch of the erstwhile firm. Thereafter, from 21st October, 1982, the assessee started a proprietary concern by the name of M/