Question of lawQuestion of factLeave to appealIncome Tax Act
Tags
Income taxAppeal procedureLeave to appeal
legislation
Statutes Cited
Income Tax Act
Income Tax Act
ai analysis
Case Summary
Key Issues
{"issue_text":"Whether appellant’s appeal raised questions of law alone permitting appeal without leave under s 66(1)(a) Income Tax Act","issue_type":"procedural","dispositive":"yes","related_facts":"All seven grounds prefixed “erred at law” but attacked factual findings"}
This summary was generated by AI. Use Zalari to read the full judgment.
background
Facts of the Case
Background
Appellant appealed to Supreme Court against Special Court judgment upholding tax assessments for various years. Respondent objected that appeal required leave because it challenged factual findings. Court examined seven grounds of appeal and concluded all attacked factual findings, rendering notice of appeal a nullity.
Read the full judgment, get AI analysis, and find related cases