Tax case appeal dismissed for lack of substantial legal questions. Tribunal's decision upheld on factual grounds.

The High Court dismissed the tax case appeal as the Tribunal's decision to remit the matter back to the Assessing Officer for determining disallowance under Section 14A did not involve substantial questions of law. Similarly, the appeal regarding reconsideration of interest free funds and borrowed funds available with the assessee was also dismissed, as the Tribunal's direction was based on factual determinations rather than legal interpretations, not warranting consideration under Section 260A.

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Issues:
1. Disallowance under Section 14A of the Income Tax Act, 1961.
2. Reconsideration of interest free funds and borrowed funds available with the assessee.

Analysis:
1. The appellant Revenue challenged the Tribunal's decision to set aside the appellate order and direct the Assessing Officer to redo the disallowance under Section 14A. The Tribunal remitted the matter back to the Assessing Officer to determine if investments were made from borrowed funds or interest free funds. The High Court observed that the appeal did not involve any substantial questions of law as the Tribunal did not provide a categorical finding on the disallowance under Section 14A. The Tribunal's decision was based on the need to identify interest free funds, not a legal question under Section 260A. Consequently, the High Court dismissed the tax case appeal.

2. The second issue involved the Tribunal's direction to reconsider the interest free funds, profits, borrowed funds, and exempted income of the assessee. The Tribunal set aside the lower authorities' orders and instructed the Assessing Officer to determine the extent of interest free funds available with the assessee. The High Court noted that the Tribunal's decision was not a legal question suitable for consideration under Section 260A. The Tribunal's remand was based on factual determinations regarding the source of funds used for investments, rather than a legal interpretation. Therefore, the High Court dismissed the appeal, emphasizing that no substantial questions of law were involved in the matter.

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