On appeal, the Court held that the Appellate Tribunal is empowered to revisit orders of the Assessing Officer as well as the First Appellate Authority and as the final forum for deciding questions of fact as well as law, it is the Tribunal’s duty to test questions of fact; however, the reasoning of the Tribunal must not be contrary to Constitutional provisions and in disregard of established facts and evidence borne on record. Order of Tribunal assessing the sale of agricultural land liable to capital gains tax was set aside. (AY. 2008-09)