Findings of fact on undisclosed investment and remand on interest issue did not raise any substantial question of law.

Findings on unexplained investment in a car and in a firm were treated as findings of fact based on appreciation of evidence, so they did not raise a substantial question of law. The issue of interest under Section 158BFA(1) was also remitted for fresh consideration after giving the assessee an opportunity to furnish further particulars. As no infirmity in the Tribunal's approach was shown, the dispute remained factual rather than legal, and no basis for appellate interference was made out.

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Issues: Whether the Tribunal's findings on undisclosed investment and levy of interest under Section 158BFA(1) gave rise to any substantial question of law warranting interference in appeal.

Analysis: The Tribunal's conclusions on the unexplained investment in the car and in the firm were based on appreciation of evidence and were treated as findings of fact. On the car issue and the interest issue, the matter had been remitted for fresh consideration after giving the assessee an opportunity to furnish further particulars. No infirmity in the Tribunal's approach was shown that would convert the dispute into a question of law.

Conclusion: No substantial question of law arose, and the appeal was liable to be dismissed.

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