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Issues: Whether the substantial questions of law arose for consideration in the appeal when the Tribunal had remanded the matter for fresh decision.
Analysis: The matter had not reached a final adjudication on the disputed points because the Tribunal had remanded it for fresh decision. In that situation, the questions proposed by the assessee were held to be premature, as they could still be urged before the appellate authority in the proceedings after remand.
Conclusion: The substantial questions of law were held not to arise for consideration at that stage, and the appeals failed.
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