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Section 144 of the Income-tax Act, 1961 - Best assessment - Block period 1987-88 to 1996-97 - In course of search at residential premises of one of partners of assessee-firm, some papers relating to assessee-firm were found which indicated that assessee-firm had undisclosed income for relevant period - Notice under section 158BC was issued asking firm to furnish return for block period - No return was filed on ground that firm had dissolved and discontinued its activities - Therefore, Assessing Officer issued notices under section 158BC read with sections 158BD and section 189(1) to all partners of dissolved firm asking them to give return for block period in respect of firm - There being no compliance to show-cause notice issued along with notice under section 142(1), Assessing Officer completed assessment as per best assessment - Whether, on facts, best assessment of Assessing Officer could be said to be vitiated by any error of law - Held, no [In favour of revenue] Section 260A of the Income-tax Act, 1961 - High Court, appeal to - Whether grounds raising new questions which are essentially questions of fact can be permitted to be raised for first time in appeal under section 260A - Held, no [In favour of revenue] Ms. Rajshree Kajaria for the Appellant. Dipak Shome and Md. Nizamuddin for the Respondent. JUDGMENT Bhaskar Bhattacharya, J - This appeal under Section 260A of the Income-tax ("Act"), 1961 is at the instance of an assessee, represented by two of its erstwhile partners, and is directed against an order dated December 17, 2003 passed by the Income-tax Appellate Tribunal, "A" Bench, Kolkata in Income-tax (SS) Appeal No.34 (Kol) of 1998 for the Block Period 1987-88 to 1996-97 up to 2nd July, 1996. 2. Being dissatisfied, two of the partners of the erstwhile partnership firm, the assessee, have come up with the present appeal. 3. The facts giving rise to filing of this appeal may be summed up thus: (a) In course of search on July 2, 1996 in the residential premises of one Bijay Kumr Gutgutia, some papers relating to the firm, M/s. Shree Krishna Arvind Hatcheries, along with other books of accounts and a bunch of papers with identification mark BKG/5 were…

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