Substantial Question of Law under Section 260A not found where deduction claim turned on factual findings about retirement benefits.

The assessee's claim for deduction in respect of gratuity and leave encashment was examined on facts, including the assessee's age and the retirement-related nature of the benefits. The lower authorities and the Tribunal had recorded factual findings, and the High Court held that the claim did not raise any debatable legal issue warranting interference under Section 260A of the Income-tax Act, 1961. Since an appeal under Section 260A lies only where a substantial question of law arises, no such question was found to exist and the appeal was dismissed as not maintainable.

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Issues: Whether the appeal under Section 260A of the Income-tax Act, 1961 raised any substantial question of law arising from the assessee's claim for deduction under Sections 10(10A) and 10(10AA) of the Act.

Analysis: The dispute turned on the assessee's entitlement to deduction in respect of gratuity and leave encashment, and the findings recorded by the lower authorities and the Tribunal were based on the facts, including the assessee's age and the nature of retirement-related benefits. The question whether the claim was allowable did not involve any debatable legal issue requiring interference in second appeal. Under Section 260A of the Income-tax Act, 1961, an appeal lies only when a substantial question of law arises.

Conclusion: No substantial question of law arose. The appeal was not maintainable under Section 260A and was dismissed, in favour of the Revenue.

Final Conclusion: The decision leaves undisturbed the factual findings on the assessee's deduction claim and refuses appellate interference at the stage of Section 260A.

Ratio Decidendi: An appeal under Section 260A of the Income-tax Act, 1961 lies only on a substantial question of law, and purely factual determinations do not warrant interference.

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