The  Assessing Officer disallowed the expenses. Tribunal restored the issue to the Assessing Officer for fresh verification. High Court held that since the findings arrived at by the Tribunal were purely factual and the order of remand could not be considered to be a question of law, thus, the appeal was dismissed. Court held that there was a gross delay of 621 days in filing the SLP, which had not been satisfactorily explained by the revenue. SLP of revenue dismissed on account of delay as well as on merits. (AY. 2010-11)