Disallowance of manpower and establishment based on surmises found unsupported; no substantial question of law arose.

A disallowance of part of the assessee's manpower and establishment expenditure, based on rental income and alleged non-business activities, was challenged as unsupported by evidence. The appellate authorities held the disallowance was made on surmises and conjectures and accepted the assessee's challenge to the assessment order. The Delhi HC found no perversity in those concurrent findings and declined to take a different view on the material before it. No substantial question of law arose, and the disallowance was not interfered with.

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Issues: Whether the disallowance of a portion of the assessee's expenditure on manpower and establishment, made on the basis of its rental income and alleged non-business activities, gave rise to any substantial question of law.

Analysis: The appellate authorities had found that the disallowance was made on surmises and conjectures and had accepted the assessee's challenge to the assessment order. The Court found no perversity in those concurrent findings and was not persuaded to take a different view on the material before it.

Conclusion: The disallowance was not interfered with, and no substantial question of law arose.

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