Substantial question of law: factual findings and recomputation under Section 80IA and Section 14A did not justify interference.

Concurrent factual findings that development and environmental expenses, meter replacement costs, and head office expenses were incurred in the course of business did not raise a substantial question of law, and those findings were left undisturbed. The Section 80IA deduction dispute over the purchase price from Tata Power Company also raised no substantial question of law because the Tribunal had already examined the computation, the proviso and explanation, and the accepted market-rate basis from earlier years. The Section 14A disallowance issue under Rule 8D likewise involved recomputation on remand and was governed by settled precedent that Rule 8D was not retrospective. The Revenue's challenge was rejected in full.

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Issues: (i) Whether the claims relating to development and environmental expenses, replacement of meters, and head office expenses gave rise to any substantial question of law; (ii) Whether the claim relating to purchase price from Tata Power Company for deduction under Section 80IA of the Income-tax Act, 1961 gave rise to any substantial question of law; (iii) Whether the issue relating to disallowance under Section 14A of the Income-tax Act, 1961 and Rule 8D of the Income Tax (Fifth Amendment) Rules, 2008 gave rise to any substantial question of law.

Issue (i): Whether the claims relating to development and environmental expenses, replacement of meters, and head office expenses gave rise to any substantial question of law.

Analysis: The Tribunal had recorded factual findings that these claims had been dealt with in the assessee's own earlier assessment years and that the relevant expenditure was incurred in the course of the assessee's business. The challenge before the Court required no legal reappraisal but only reconsideration of facts already accepted in earlier years. The Revenue also failed to show any cogent basis for disturbing those findings.

Conclusion: No substantial question of law arose on these claims, and the findings were left undisturbed in favour of the assessee.

Issue (ii): Whether the claim relating to purchase price from Tata Power Company for deduction under Section 80IA of the Income-tax Act, 1961 gave rise to any substantial question of law.

Analysis: The Tribunal had examined the computation of deduction under Section 80IA, including the proviso and explanation, and noted that for earlier assessment years the Revenue had accepted the purchase rate as market value. The Tribunal also considered the material relating to the Maharashtra Electricity Regulatory Authority and found no basis to hold that the rate fixed by it represented the true market value. The challenge was, in substance, an attempt to reopen factual determinations and the mode of computation accepted in earlier years.

Conclusion: No substantial question of law arose on the Section 80IA claim, and the issue was decided against the Revenue.

Issue (iii): Whether the issue relating to disallowance under Section 14A of the Income-tax Act, 1961 and Rule 8D of the Income Tax (Fifth Amendment) Rules, 2008 gave rise to any substantial question of law.

Analysis: The Tribunal had applied the then governing precedent and directed computation on a reasonable basis having regard to the relevant facts and circumstances. It had also directed reconsideration by the Assessing Officer. In view of the settled position that Rule 8D was not to be applied retrospectively, and because the matter involved a recomputation on remand, no substantial question of law survived.

Conclusion: No substantial question of law arose on the Section 14A and Rule 8D issue, and the matter stood in favour of the assessee.

Final Conclusion: The appellate challenge was rejected in entirety because the questions raised were either factual, already settled by earlier years, or governed by binding precedent, and no substantial question of law was shown to exist.

Ratio Decidendi: Concurrent findings of fact and matters requiring only recomputation or remand, especially where governed by binding precedent, do not give rise to a substantial question of law.

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