Fact-bound tax questions and previously decided disallowance issue were not separately entertained in the appeal.

A proposed additional question under section 40(a)(ia) was not separately entertained because it had already been decided against the Revenue in the assessee's own case. The remaining proposed question on unexplained expenditure was treated as purely fact-bound, as it arose from the Tribunal's findings and did not raise any question of law. The appeal therefore proceeded only on the admitted substantial question of law, while the additional questions were declined for separate consideration or rejected as non-justiciable questions of law.

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Issues: Whether the proposed additional question relating to disallowance under section 40(a)(ia) of the Income-tax Act, 1961 required separate consideration, and whether the additional question on unexplained expenditure gave rise to a question of law.

Analysis: The proposed question under section 40(a)(ia) had already been decided against the Revenue in the assessee's own case and was therefore not taken up for separate discussion. The remaining proposed question concerning unexplained expenditure was held to arise purely from the facts found by the Tribunal and was not treated as giving rise to any question of law.

Conclusion: The first additional question was not independently considered, and the second additional question was rejected as not raising any question of law.

Final Conclusion: The appeal proceeded only on the admitted substantial question of law, while the additional proposed questions were either declined for separate consideration or held not to warrant adjudication as questions of law.

Ratio Decidendi: A proposed question will not be separately entertained where it has already been answered in the assessee's favour in an earlier decision, and a fact-bound issue does not give rise to a substantial question of law.

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