Factual estimate of construction cost did not raise a substantial question of law under income-tax appeal provisions.

A purely factual dispute over the estimated cost of construction did not give rise to a substantial question of law under section 260A of the Income-tax Act. The Tribunal's valuation of the cinema hall was treated as a fair middle course on the material before it, and no perversity was found in that estimate. As the controversy concerned factual assessment rather than a legal principle, the appeal could not be admitted under section 260A, and the Tribunal's order was left undisturbed.

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Issues: Whether any substantial question of law arose under section 260A of the Income-tax Act, 1961 in relation to the Tribunal's estimate of the cost of construction and the consequent application of section 69B of the Income-tax Act, 1961.

Analysis: The dispute concerned only the factual estimation of the cost of construction of the cinema hall. The Tribunal's estimate was treated as a fair middle course on the material before it, and no perversity was found in its approach. Since section 260A permits an appeal only on a substantial question of law, a purely factual controversy did not justify admission.

Conclusion: No substantial question of law arose. The appeal was not admitted and the Tribunal's order stood confirmed.

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