No substantial question of law arises where section 11 exemption was already consistently upheld on the same facts.

Where the same assessee's claim for exemption under section 11 had already been consistently accepted in earlier years on the same facts, the HC held that no substantial question of law arose under section 260A. The Tribunal's view granting charitable status and exemption was in line with those prior decisions, and no fresh legal issue justifying interference was shown. The Revenue's appeal was dismissed.

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Issues: Whether the Revenue's appeal under section 260A of the Income-tax Act, 1961 raised any substantial question of law against the Tribunal's grant of exemption under section 11 of the Income-tax Act, 1961.

Analysis: The appeal was examined in the light of earlier orders concerning the same assessee and the same issue, where the Department's challenges had already been dismissed. The Court found that the Tribunal's view allowing charitable status and exemption under section 11 was consistent with those prior decisions. No fresh question warranting interference was shown.

Conclusion: No substantial question of law arose for consideration and the appeal was dismissed.

Ratio Decidendi: Where the controversy on exemption under section 11 has already been consistently resolved in favour of the assessee in earlier years on the same facts, no substantial question of law arises in a further appeal under section 260A.

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