Substantial question of law: Tribunal's factual finding on effective transfer date of property upheld, defeating the revenue challenge.

The revenue's challenge to the Tribunal's finding on the effective date of transfer of immovable property failed because the issue turned on accepted factual findings and a permissible view of the transaction. The Tribunal had held that taxability attached from the date the full sale consideration was received, relying on the terms of the individual transaction and on earlier findings in the assessee's own case that had not been appealed. As the record did not support the revenue's claim about possession, the High Court held that no substantial question of law arose and rejected the appeal.

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Issues: Whether the revenue appeal raised any substantial question of law on the Tribunal's finding as to the effective date of transfer of immovable property and the consequent assessability of the sale proceeds.

Analysis: The appeal challenged the Tribunal's view that the relevant date for taxing the transaction was the date on which the entire sale consideration was received. The Tribunal's conclusion was based on the terms of the individual transaction and on findings already accepted in prior assessment years in the case of the same assessee. No appeal had been shown to have been filed against those earlier findings, and the facts found by the Tribunal in the present and earlier years showed that the possession of the immovable property was not taken or retained in the manner now urged by the revenue. The view taken by the Tribunal was held to be a possible view on the facts and circumstances.

Conclusion: No substantial question of law arose, and the appeal failed.

Final Conclusion: The revenue's challenge was rejected because the dispute turned on accepted factual findings and a permissible view of the transaction, leaving no substantial question of law for consideration.

Ratio Decidendi: Where the Tribunal's conclusion on the nature and effective date of a property transfer is supported by concurrent factual findings and is a possible view on the record, the High Court will not treat the matter as giving rise to a substantial question of law.

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