Where the Assessing Officer disallowed 5 per cent of the total expenditure claimed by the assessee on the ground that the expenditure involved a personal element and no log book had been maintained, and the Commissioner (Appeals) and Tribunal confirmed the disallowance, the High Court held that the findings of the authorities were purely factual in nature and did not give rise to any substantial question of law. Where the assessee claimed commission payments to two individuals for services allegedly rendered, but the authorities disallowed the claim on the ground that the recipients lacked knowledge of the assessee’s business and could not have rendered the alleged services, the High Court held that the disallowance was based on the statements recorded and appreciation of facts by the authorities and, therefore, the findings being purely factual did not give rise to any substantial question of law