No substantial question of law arises where a Supreme Court ruling already governs reassessment for the same assessee and years.

An appellate challenge to reassessment could not proceed where the Tribunal had relied entirely on a Supreme Court ruling already quashing reassessment for the same assessee and common assessment years. Because that ruling covered the assessment year in question and the notice was based only on an alleged permanent establishment in India after arm's length procedure had already been followed, the High Court held that no substantial question of law arose. The appeal was therefore not entertained on merits and stood dismissed.

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Issues: Whether the appeal raised any substantial question of law in view of the Supreme Court's decision quashing reassessment proceedings for the same assessee and common assessment years.

Analysis: The impugned order of the Tribunal had proceeded entirely on the basis of the Supreme Court's ruling that reassessment could not be sustained where the arm's length procedure had already been followed and the notice was founded only on the allegation of a permanent establishment in India. Since that ruling applied to the assessment year in question as part of the same group of years, the basis of the Tribunal's decision stood covered. On that footing, no substantial question of law arose for consideration in the appeal.

Conclusion: The appeal was not entertained on merits and stood dismissed.

Final Conclusion: The reassessment challenge failed because the Supreme Court's common ruling governed the controversy, leaving no substantial question of law arising from the Tribunal's order.

Ratio Decidendi: Where the impugned order is wholly founded on a Supreme Court decision governing the same controversy and assessment years, no substantial question of law arises for interference under appellate jurisdiction.

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