HC denied to admit appeal as issue relating to valuation of assets made by ITAT was question of fact

WT : Where Tribunal relying upon its orders passed in earlier assessment years, reduced valuation adopted by Departmental valuer in respect of beneficial interest of assessee in jewellery held by a trust on account of various factors such as joint ownership, cumulative burden of tax liabilities, hazard and risk of litigation etc., said question relating to valuation of asset being a pure question of fact, impugned order passed by Tribunal did not require any interference.