Paragraph 34 in Schedule 5 to the Income Tax Act 1976 (“ITA 1976”) — Primary findings of facts by SCIT generally unassailable and can neither be overruled not supplemented by the High Court — Paragraphs 34(1) and 39 in Schedule 5 to the ITA 1967 empower courts to hear appeals based on questions of law — Paragraph 34A(3) in Schedule 2 to the RPGTA 1976 provides formula for the determination of the acquisition price of the Rights Share for purposes of assessment under the RPGTA 1976 — whether SCIT erred in law in applying paragraph 4 instead of paragraph 9 in Schedule 2 to the RPGT Act 1976 in the determination of the acquisition price of the Rights Shares 3 cases