JUDGMENT : Tashi Rabstan, J. 1. This Appeal, filed under Section 260-A of the Income Tax Act, 1961 is directed against the order dated 02.01.2015 passed by the Income Tax Appellate Tribunal, Amritsar Bench in ITA No. 178/Asr/2013 (assessment year 2009-10), whereby, while allowing the appeal of assessee-respondent herein, the learned Tribunal, has held the assessee entitled for the deduction 80-IE of the Income Tax Act, as also excise duty refund has been held to be capital receipts, besides it was also held that the learned CIT(A) was not justified in disallowance of interest. The facts-in-brief are that the assessee-Company had claimed deduction under Section 80-IE of the Income Tax Act amounting to Rs. 1,33,10,413/-, which the Assessing Officer disallowed on the ground that conversion of gold into gold powder does not amount to manufacture. Further, the excise duty refund of Rs. 82,48,402/-, which the assessee-Company had received as consequent to the scheme formulated by the Government of India and was claimed as deduction under Section 80-IE of the Act being corresponding to the receipt of said refund, was held by the Assessing Officer to be derived from industrial undertaking and accordingly, the same was added to the income of assessee. Also, the interest paid to the bank by the assessee-Company to the extent of interest free advance/investment, amounting to Rs. 2,29,550/-, was disallowed by the Assessing Officer and added the same to the income of assessee. 2. On an appeal filed by the assessee, the Commissioner of Income Tax (Appeals) vide its order dated 30.01.2013 passed in Appeal No. 389/11-12, rejected the claim of assessee. Against the said order, assessee-company went in appeal before the Income Tax Appellate Tribunal, Amritsar Bench, Amritsar (hereinafter, for short, Appellate Tribunal). 3. Appellate Tribunal vide its detailed order dated 02.01.2015 allowed the appeal of assessee, respondent herein, holding the assessee entitled for the deduction 80-IE of the Income Tax Act, besides excise-duty refund was held to be capital receipts. It was also held that the learned CIT(A) was not justified in disallowance of interest. Hence, the present appeal on behalf of appellant. 4. We have heard learned counsel for both the sides and also gone through the file minutely. 5. It was also held that the learned CIT(A) was not justified in disallowance of interest. Hence, the present appeal on behalf of appellant. 4. We have heard learned counsel for both the sides and also gone through the file minutely. 5. Though an obligation is cast on the appellant to precisely state in the memorandum of appeal the substantial question of law involved in the appeal and which the appellant proposes to urge before the Court, however, it is for this Court to see whether there is any substantial question of law in the case and only then the same has to be formulated by the Court. In the present case, although the appellant has raised as many as six substantial questions of law, however, in our opinion neither the same can be formulated nor taken into consideration simply in view of the fact that the Tribunal has delivered a detailed judgment on factual finding of facts. Interference with the finding of facts by this Court is not warranted if it invokes re-appreciation of evidence. Since the Tribunal has delivered a detailed judgment on factual finding of facts, no substantial question of law can be framed in an appeal arisen thereto. Under Section 260-A of the Income Tax Act, the appeal can be admitted for final hearing only when it involves any substantial question of law. Since none of the questions sought to be raised by the appellant satisfies the rigour of Section 260-A of the Income Tax Act, being the impugned judgment is on factual finding of facts, the appeal is liable to be dismissed and the impugned judgment of Tribunal being invincible, needs to be upheld. Viewed thus, we do not find any merit in the appeal and the same is, accordingly, dismissed along with connected miscellaneous petition, if any, upholding the judgment of Appellate Tribunal.