Section 10B deduction turns on factual findings where no substantial question of law arises in appeal.

The dispute concerned whether the assessee's entitlement to deduction under Section 10B of the Income-tax Act, 1961 gave rise to any substantial question of law in appeal. The Bombay High Court noted that the Tribunal's conclusion rested on factual appreciation of the assessee's activities, the materials on record, and the absence of distinguishable contrary facts. It also relied on the Tribunal's earlier decision in the assessee's own case and found that the statutory conditions for deduction were satisfied. Because the Revenue did not effectively challenge that factual foundation, the challenge did not disclose any legal issue warranting interference, and the deduction was upheld.

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Issues: Whether any substantial question of law arose from the Tribunal's finding that the assessee was entitled to deduction under Section 10B of the Income-tax Act, 1961.

Analysis: The dispute turned on factual appreciation of the assessee's activity, the materials placed on record, and the absence of any distinguishable or contrary facts. The Tribunal had relied upon its earlier decision in the assessee's own case and recorded a factual conclusion that the conditions for deduction were satisfied. As the grounds of appeal did not effectively challenge that factual foundation, the controversy did not raise a legal issue warranting interference in appeal.

Conclusion: No substantial question of law arose, and the Revenue's challenge to the allowance of deduction under Section 10B failed.

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