Dismissing the appeal of the revenue the Court held that; the Tribunal having factually determined the value of assets transferred to the partnership as on April 1, 2011 and rejected the contention of the Department that the value of assets would have to be taken into consideration the court could not entertain any appeal under section 260A of the Income-tax Act, 1961. The right of appeal is not automatic but is conferred by statute. When the statute confers a limited right of appeal only in a case which involves substantial questions of law, it is not open to the High Court to sit in appeal over the factual findings arrived at by the Appellate Tribunal. For the purpose of computing capital gains value of assets  recorded in books of the firm on date of transfer would be deemed to be full value of consideration received as a result of transfer  No question of law arose. Followed M. Janardhna Rao v. JCIT ( 2005) 273 ITR 50 (SC) ( AY.2012-13)