Substantial question of law was rejected where the Tribunal had already considered the relevant contentions in the appellate order.

The Revenue contended that a substantial question of law arose because the Tribunal had not separately dealt with every ground raised before it. The Court held that no such question arose for consideration, as the rectification applications had already been rejected on the basis that the original appellate order had considered the relevant contentions. In the absence of any separate adjudicatory error warranting interference, the appeal was not entertained.

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Issues: Whether the appeal gave rise to a substantial question of law on the ground that the Tribunal had not dealt with all the grounds raised before it.

Analysis: The Revenue's challenge was founded on the complaint that the Tribunal's order was incomplete because it had not separately discussed every ground. The Court found that the proposed question did not arise for consideration in the appeal. The rectification applications had already been rejected on the footing that the original appellate order had considered the contentions raised, and no separate adjudicatory error was shown that would warrant interference.

Conclusion: No substantial question of law arose, and the Revenue's appeal was not entertained.

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