Binding precedent bars substantial question of law where surplus-fund interest and retirement-benefit deduction issues are already settled.

Interest on surplus funds was held taxable as income from other sources because binding precedent was conclusive against the Revenue, so that issue was decided in favour of the assessee. The provision for retirement benefits was held not allowable as a deduction under section 37 because prior precedent had already decided the point against the assessee, so that issue was decided in favour of the Revenue. As both questions were covered by binding precedent, no substantial question of law arose under section 260A and the appeal was dismissed.

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Issues: Whether the interest income earned on surplus funds was taxable as income from other sources, and whether the provision for retirement benefits was allowable as a deduction under section 37.

Issue (i): Whether the interest income earned on surplus funds was taxable as income from other sources.

Analysis: The issue was covered by binding precedent of the Court, which was treated as conclusive and adverse to the Revenue.

Conclusion: The issue was decided against the Revenue and in favour of the assessee.

Issue (ii): Whether the provision for retirement benefits was allowable as a deduction under section 37.

Analysis: The issue was covered by binding precedent of the Court, which had held against the assessee on allowability of such deduction.

Conclusion: The issue was decided in favour of the Revenue and against the assessee.

Final Conclusion: No substantial question of law arose for consideration, and the appeal was dismissed.

Ratio Decidendi: Where the issues raised in an appeal are already concluded by binding precedent, no substantial question of law arises under section 260A.

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