Tribunal remand based on factual appreciation did not raise any substantial question of law.

An appeal against a Tribunal's remand order was held not to raise any substantial question of law. The Tribunal had followed its earlier decision in the same assessee's case for prior assessment years, and the impugned remand was treated as arising from factual appreciation rather than any legal controversy. On that basis, the court treated the remand as a factual order and concluded that it did not give rise to a question of law, much less a substantial question of law. The appeal was therefore not maintainable on that ground.

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Issues: Whether the appeal against the Tribunal's order of remand raised any substantial question of law warranting interference.

Analysis: The Tribunal had relied on its earlier decision in the same assessee's case for prior assessment years, and the present impugned order was found to be based on factual appreciation. The remand made by the Tribunal was treated as a factual order, and such remand was held not to give rise to a question of law, much less a substantial question of law.

Conclusion: No substantial question of law arose for consideration, and the appeal was not maintainable on that basis.

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