Substantial question of law under Section 260A not established, so Tribunal order sustained based on affirmed precedent.

Whether a substantial question of law exists under Section 260A was tested against the Tribunal's reliance on an earlier High Court judgment that was later affirmed by the Supreme Court; the legal principle applied is that Section 260A permits interference only where a distinct substantial question of law is shown. Because no new or distinct legal question was demonstrated and the Tribunal followed an affirmed precedent, interference was unwarranted and the appellate challenge under Section 260A failed, leaving the Tribunal's order undisturbed in favour of the respondent.

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Issues: Whether the Revenue has raised any substantial question of law under Section 260A of the Income-tax Act, 1961 warranting interference with the order of the Income Tax Appellate Tribunal which followed a prior judgment of this High Court affirmed by the Supreme Court.

Analysis: The appeal under Section 260A was examined in the context of the Tribunal having relied upon an earlier judgment of this High Court in respect of the same assessee for a prior assessment year. That earlier High Court judgment was subsequently challenged before the Supreme Court in S.L.P.No.19564 of 2018 and the Supreme Court dismissed the special leave petition, leaving the High Court decision intact. Given that the Tribunal's decision is founded on a High Court judgment which has been affirmed by the Supreme Court, the legal framework under Section 260A requires the existence of a substantial question of law to permit interference. In the absence of any distinct or new legal question shown by the Revenue and in light of the affirmed precedent, no substantive question of law is made out for the purposes of Section 260A.

Conclusion: No substantial question of law is made out; the appeal is dismissed and the Tribunal's order upheld in favour of the respondent.

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