No substantial question of law arose where findings were factual and the remaining issue was covered by binding precedent.

The Tribunal's finding that there was no business and no material supporting a bogus reimbursement claim was treated as a pure finding of fact, so no substantial question of law arose from Questions 5.1 to 5.3. Question 5.4 was also not separately considered because it was already covered by the binding precedent in Reliance Utilities & Power Ltd. The framed questions therefore did not justify appellate interference.

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Issues: (i) Whether Questions 5.1 to 5.3 gave rise to any question of law where the Tribunal had found, on the facts, that there was no business and no material to show a bogus claim of reimbursement of expenditure; (ii) Whether Question 5.4 survived for consideration in view of the binding precedent relied on by the Court.

Issue (i): Whether Questions 5.1 to 5.3 gave rise to any question of law where the Tribunal had found, on the facts, that there was no business and no material to show a bogus claim of reimbursement of expenditure.

Analysis: The Tribunal's conclusion rested on appreciation of the record and was treated as a pure finding of fact. On that footing, no substantial question of law arose from Questions 5.1 to 5.3.

Conclusion: Questions 5.1 to 5.3 did not give rise to any question of law.

Issue (ii): Whether Question 5.4 survived for consideration in view of the binding precedent relied on by the Court.

Analysis: The question was covered by the earlier decision of the Court in Reliance Utilities & Power Ltd., and therefore did not require separate adjudication.

Conclusion: Question 5.4 did not survive for consideration.

Final Conclusion: The appeal was rejected as none of the framed questions warranted interference in the Court's appellate jurisdiction.

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