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Issues: Whether any substantial question of law arose for consideration, or whether the controversy was confined to factual issues.
Analysis: The appeal was examined on the basis of the facts found in the record, and the Court concluded that the dispute turned entirely on factual appreciation. No substantial question of law was found to arise.
Conclusion: The issue was decided against the appellant and in favour of the Revenue.
Final Conclusion: The appeal stood dismissed as no legal question warranting interference was made out.
Ratio Decidendi: Where the entire controversy is factual and no substantial question of law arises, the appellate court will not interfere.