The assessees were non-banking finance and leasing companies registered with the Reserve Bank of India and credit institutions within the meaning of section 2(5A) of the Interest-tax Act, 1974. Some of the assessees were hire-purchase finance companies which under hire-purchase agreements, hired out vehicles to customers. The Tribunal recorded findings of fact that under the hire-purchase agreements, the assessees were the owners of the vehicles, the hirer must pay rent to the owner during the hiring as in the agreement on the dates mentioned therein, the hirer had to take proper care of the vehicle and keep it in good condition, pay all rents, rates, taxes and outgoings payable, keep the vehicle in his sole custody and possession at the address mentioned in the agreement, if the hirer failed to pay the hire instalments within the stipulated time, became insolvent, pledged or sold, or attempted to pledge or sell or otherwise alienate or transfer the vehicle, or did or suffered any act or thing whereby, or in consequence of which, the vehicle may be distrained, seized or taken into execution under legal process, or broke or failed to perform or observe any condition as mentioned in the hire-purchase agreement, the owner was entitled to forthwith determine the agreement and, thereupon, enter the place where the vehicle was kept and seize, remove and retake possession thereof, the owner was also entitled to sue for all the instalments due, damages for breach of the agreement, and the cost in retaking possession of the vehicle, the owner, if agreeable, might permit the hirer to have the registration of the vehicle in his own name, provided that the hirer shall transfer the registration in the name of the owner whenever required to do so by the owner, especially when the hirer committed breach of any of the conditions of the agreement, due to which the owner was obliged to seize the vehicle. On these facts, the Tribunal accepted the plea of the assessees that they were not liable to pay interest-tax on the interest component imbedded in the hire-purchase instalment. The High Court reversed the finding of the Tribunal, observing that the hire-purchase instalment included “finance charges”, which were nothing but interest, and therefore, interest-tax was leviable on the interest component. On appeals , allowing the appeals, that the High Court did not frame a specific substantial question of law and thus, interference with the findings of fact was unwarranted. This did not mean that the tax authorities were 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. However, remanding the matters to the Assessing Officer for fresh adjudication and to re-examine all the transactions keeping in mind the dictum laid down in Sahara India Savings and Investment Corporation Ltd( 2010)) 321 ITR 371 (SC),  and State Bank of Patiala ( 2016) 383 ITR 244 ( SC)  to rule out cases where camouflage or subterfuge had been adopted to avoid payment of interest-tax, would entail not only looking at the documents but also several other factors, which would mean getting information and ascertainment of facts in detail from the assessee and the hirer. Hence, at this distant point of time, it would not be appropriate to pass an order of remand. Also, the Act had ceased to operate with effect from March 31, 2000. Therefore, the additions made by the Assessing Officer were to be set aside and the orders passed by the Tribunal deleting the additions in the case of the assessee and other cases were to be upheld . Findings of fact generally recorded by the Tribunal are treated as conclusive. 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. Ratio of judgments relating to one tax enactment not to be treated as precedent in case relating to another tax enactment .Especially when language, object and purpose of  enactments are different .