Reversing the order of High Court the Court held that the High Court can interfere with findings of fact while deciding a substantial question of law when the findings are not supported by the material on record, so as to be treated as perverse. For this, however, the High Court must frame a separate substantial question of law and only then interfere with the findings of fact recorded by the Tribunal, while applying strict parameters.
Muthoot Leasing and Finance Ltd. v. CIT (2023) 450 ITR 496 /292 Taxman 5 / 330 CTR 209 (SC)
S. 260A : Appeal-High Court-Finding of fact-High Court must frame the substantial question of law-Order setting aside the order of Tribunal was quashed and set aside-Order of Tribunal was affirmed. [Interest-tax Act, 1974, S. 2(5A), 2(5B), 2(7)]