AO issued notice under S. 148 to assessee on ground that assessee made various provisions, namely, for gratuity, doubtful debts, warranty, and obsolescence which were in nature of unascertained liabilities and were not added to book profit resulting in under assessment of income and disallowed 20 per cent of said provision and made addition to closing stock. Tribunal held that the notice was issued on account of change of opinion hence bad in law. High Court dismissed revenue’s appeal against Tribunal’s order in limine holding that it did not involve any substantial question of law. Supreme Court held that High Court was not justified in dismissing appeal on ground that appeal did not Involve any substantial question of law and case was remanded to High Court for deciding revenue’s appeal afresh on merits in accordance with law after framing substantial question of law in accordance with law. (AY. 1999-2000)