Substantial Question of Law in Income Tax Appeals: valuation report dispute did not justify interference under section 260A.

An appeal under section 260A of the Income-tax Act lies only where a substantial question of law arises, meaning an issue of substance with a material bearing on the parties' rights. On the facts considered, the challenge to the Tribunal's setting aside of revision under section 263, based on alleged non-furnishing of a valuation report, did not raise a question of law or a mixed question of law and fact. The Court also noted the principle that where a property owner or occupier does not cooperate in valuation, best judgment valuation may be adopted. No substantial question of law arose and the appeal was not entertainable on merits.

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Issues: Whether the appeal disclosed a substantial question of law under section 260A of the Income-tax Act, 1961 in relation to the Tribunal's setting aside of the revisional order under section 263 on the issue of non-furnishing of the valuation report.

Analysis: The appeal lay only if the case involved a substantial question of law. The expression "substantial question of law" carries a settled meaning and must raise an issue of substance having a material bearing on the rights of the parties. On the facts placed before the Court, the challenge centered on the absence of a valuation report in a situation where the assessee allegedly did not cooperate. The Court held that this grievance did not give rise to either a question of law or a mixed question of law and facts. The Tribunal's approach was also supported by the principle that where a property owner or occupier does not cooperate in valuation, best judgment valuation may be adopted.

Conclusion: No substantial question of law arose and the appeal was not entertainable on merits.

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