Substantial question of law absent in factual tax disallowance disputes; appellate interference was refused and assessee relief stood.

The appeal challenged factual findings on disallowance of excessive payment to directors, excess rebate and discount, bad debts, and ad hoc expenditure. The HC held that the Tribunal had already examined these matters as questions of fact and had affirmed the Commissioner (Appeals)'s conclusions in favour of the assessee. As the grounds raised did not disclose any debatable legal issue or substantial question of law, the court declined interference in appellate jurisdiction and dismissed the appeal, leaving the assessee's relief undisturbed.

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Issues: Whether any substantial question of law arose from the Tribunal's decision on the factual disallowance and addition issues.

Analysis: The appeal sought to challenge findings relating to disallowance of excessive payment to directors, excess rebate and discount, bad debts, and ad hoc expenditure. The Tribunal had already examined these matters as questions of fact and had affirmed the factual conclusions reached by the Commissioner (Appeals) in favour of the assessee. The High Court found that the questions raised were factual in nature and did not disclose any debatable legal issue warranting interference under the appellate jurisdiction.

Conclusion: No substantial question of law arose. The appeal was dismissed, leaving the assessee's relief intact.

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