Taxability of interest on government-related deposits treated as a factual issue, with no substantial question of law arising.

Interest accrual on deposits held on behalf of the Government was treated as a predominantly factual tax issue, and the HC found that the authority below had correctly and completely determined the relevant factual matrix. Because the appeal did not raise any substantial question of law, no legal basis existed for appellate interference, and the appeal failed. The decision turns on the character of the Board's transactions and the factual appreciation of the taxability of the interest income, rather than on any unsettled legal principle.

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Issues: Whether any substantial question of law arose for consideration in the appeal concerning the taxability of interest accrued on deposits held by the respondent-Board.

Analysis: The dispute turned on the character of the respondent-Board's transactions on behalf of the Government and on the appreciation of the factual matrix by the authority below. The Court found that the issue of accrual taxability of the interest on deposits was essentially factual and had been correctly and completely determined by the authority below. In these circumstances, no substantial question of law was made out.

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

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