ORDER : Delay condoned. 2. Leave granted. 3. Heard Mr. Parcival Billimoria, learned counsel for the appellant and Mr. Ranjit Kumar, learned Solicit or General for the respondent. 4. Having heard learned counsel for the parties, we are of the considered opinion that the High Court should have framed the substantial question of law pertaining to the issue whether in the facts and circumstances of the case, the assessee had taken recourse to any kind of colourable devise to evade the tax. 5. The appeal stands allowed accordingly. No order as to costs.