In Brief
The Supreme Court held that the High Court erred in allowing wealth tax appeals filed by the Revenue under Section 27-A of the Wealth Tax Act without first formulating the substantial question(s) of law. Since Section 27-A is identically worded to Section 100 of the Code of Civil Procedure, the same principles apply: formulating substantial questions of law is sine qua non for the High Court to exercise appellate jurisdiction. The High Court's failure to identify and formulate such questions rendered its decision legally unsustainable. The appeals were allowed and remanded to the High Court to decide the matter afresh in compliance with this procedural requirement.
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