High Court's interference with ITAT's factual findings requires a substantial legal question under Interest-Tax Act, 1974.

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....Liability to pay tax under the Interest-Tax Act, 1974 - the High Court must frame a separate substantial question of law and only then interfere with the findings of fact by the ITAT, while applying the strict parameters. In the present case, the High Court did not frame a specific substantial question of law and thus, the interference with the findings of fact is unwarranted. This is not to say that the tax authorities are not entitled to examine the surrounding facts and circumstances to ascertain the true character and nature of the transaction, regardless of the nomenclature given by the parties. - the Act has ceased to operate with effect from 31st March 2000 - Additions deleted - SC....