Identical issue already decided against Revenue; no substantial question of law arose in the Section 260A appeal.

The Delhi High Court held that no substantial question of law arose in the Revenue's Section 260A appeal challenging the assessee's entitlement to Section 11 exemption. The Court noted that the same charitable-status issue had already been decided against the Revenue in earlier assessment years, including prior appeals involving identical questions. Because the matter had been settled on the same point in earlier years, the Revenue's challenge on the identical issue could not be reopened as a substantial question of law, and the appeal failed.

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Issues: Whether any substantial question of law arose in the Revenue's appeal concerning the assessee's entitlement to claim benefit of Section 11.

Analysis: The appeal under Section 260A of the Income-tax Act, 1961 was founded on the challenge to the assessee's charitable status and the claim for exemption under Section 11. The Court noted that the same issue had already been decided in earlier years against the Revenue, including prior dismissal of appeals involving identical questions. In view of the earlier orders, the matter no longer gave rise to any substantial question of law.

Conclusion: No substantial question of law arose, and the Revenue's appeal failed.

Ratio Decidendi: Where an identical issue has already been decided against the Revenue in earlier years, no substantial question of law arises in a subsequent appeal under Section 260A of the Income-tax Act, 1961 on the same point.

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