Remand for verification of additional evidence under income-tax law did not raise a substantial question of law.

A remand by the Tribunal for fresh appellate examination of additions under section 68, after confirmation letters were filed as additional evidence and verification remained incomplete, was treated as a permissible procedural course. The appellate authority was expected either to examine the evidence itself under section 250(4) or seek verification from the Assessing Officer, and the Tribunal's direction for fresh decision was viewed as a possible view of the matter. As no prejudice to the assessee was shown, the remand order was held not to raise any substantial question of law under section 260A of the Income-tax Act, 1961.

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Issues: Whether the Tribunal was justified in remanding the addition matter to the Commissioner of Income-tax (Appeals) for fresh examination after additional evidence was filed.

Analysis: The appeal under section 260A arose from additions made under section 68. Additional evidence in the form of confirmation letters had been produced before the Commissioner of Income-tax (Appeals), and the Assessing Officer had not completed verification. The Tribunal held that the appellate authority should either have itself examined the matter under section 250(4) or obtained verification from the Assessing Officer, and therefore remitted the issue for fresh decision. The Court held that this was only a remand on a possible view of the matter and that no prejudice was caused to the assessee.

Conclusion: The remand order did not give rise to any substantial question of law and was upheld.

Ratio Decidendi: A remand directed for proper verification of additional evidence and fresh appellate consideration, when taken on a possible view and without causing prejudice, does not by itself raise a substantial question of law under section 260A of the Income-tax Act, 1961.

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