https://www.taxtmi.com/caselaws?id=275435 In an appeal under section 260A, a substantial question of law arising from the record may be considered even if it was not urged before the Tribunal, provided no fresh factual inquiry is needed. The decision also held that a payment for shortfall in maturity period was not a penalty, because its substance was that of an additional levy rather than a penal charge, and it could not be treated as fee or excise duty absent quid pro quo. Further, a payment towards adhesive labels was characterised by the governing rule as the cost of labels, not a fee. The Revenue's challenge therefore failed on all substantive grounds. en-us Thu, 04 Dec 2003 00:00:00 +0530 Wed, 03 Oct 2018 17:51:05 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=275435 In an appeal under section 260A, a substantial question of law arising from the record may be considered even if it was not urged before the Tribunal, provided no fresh factual inquiry is needed. The decision also held that a payment for shortfall in maturity period was not a penalty, because its substance was that of an additional levy rather than a penal charge, and it could not be treated as fee or excise duty absent quid pro quo. Further, a payment towards adhesive labels was characterised by the governing rule as the cost of labels, not a fee. The Revenue's challenge therefore failed on all substantive grounds. Case-Laws Income Tax Thu, 04 Dec 2003 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=275435