JUDGMENT : A.K. Jayasankaran Nambiar, J. 1. This Income Tax Appeal preferred by the assessee impugns the order dated 28.12.2023 of the Income Tax Appellate Tribunal, Cochin Bench in ITA No. 996/Coch/2012 & S.A. No. 89/Coch/2022, pertaining to the assessment year 2007-2008. 2. The brief facts necessary for the disposal of this Income Tax Appeal are as follows: The assessee, who was an employee of the State Bank of Travancore during the year 2006-2007 relevant to the assessment year 2007-2008 opted for the Exit Option Scheme (E.O.S.) formulated by the employer. By way of the benefits under the E.O.S. she received an amount of Rs.10,25,690/- in that year. The assessee while filing a return of income for the assessment year 2007-2008, returned an income of Rs.7,37,250/-. The said return of income included income from salary as also income from house property. The return was processed under Section 143(1) and a refund (including interest thereon) of Rs.1,71,330/- was granted to the assessee. 3. It would appear that subsequently a revised return was filed by the assessee on 14.08.2008 returning an income of Rs.6,88,420/-. The revised return was processed under Section 143(1) and a demand of Rs.2,25,580/- was raised owing to non-allowance of credit for TDS. When the assessee then took up the matter with the Assessing Authority, the latter on verification of the returns filed by the assessee found that while processing the return initially the assessee's claim for exemption under Section 10(10C) of the Income Tax Act amounting to Rs.5,00,000/- had been allowed. Since the Assessing Authority found that no Voluntary Retirement Scheme as stipulated under Section 10 (10C) of the Income Tax Act had been framed by the State Bank of Travancore where the assessee was employed, and the exemption under Section 10(10C) had been wrongly allowed, he proceeded to re-open the case under Section 147 of the Income Tax Act by issuing a notice under Section 148 thereof. The proceedings that ensued resulted in a differential demand being made on the assessee consequent to dis-allowance of the claim for exemption under Section 10(10C). 4. Aggrieved by the order of the Assessing Officer, the assessee preferred an appeal before the First Appellate Authority, which confirmed the order of the Assessing Officer. The proceedings that ensued resulted in a differential demand being made on the assessee consequent to dis-allowance of the claim for exemption under Section 10(10C). 4. Aggrieved by the order of the Assessing Officer, the assessee preferred an appeal before the First Appellate Authority, which confirmed the order of the Assessing Officer. A further appeal preferred by the assessee before the Income Tax Appellate Tribunal culminated in the order impugned in this appeal, which dismissed the appeal preferred by the assessee. The assessee is now before us, raising the following substantial questions of law: i) whether in the Learned Tribunal went wrong in disallowing exemption under Section 10(10C) of the Act? ii) Has not the Learned Tribunal went wrong in disallowing the claim which was initially allowed in 2007 and later claimed in 2014? iii) Is not the appellant entitled for exemption under Section 10(10C) of the Act? 5. We have heard the learned Senior counsel Sri. George A. Cherian, assisted by the learned counsel Smt. Latha Susan Cherian and Sri. Jose Joseph the learned standing counsel for the Income Tax Department. 6. On a consideration of the rival submissions, we find that the authorities below have clearly found, as a matter of fact, that the Clauses in the E.O.S framed by the State Bank of Travancore, and on the strength of which the assessee received the amount of Rs.10,25,690/- mentioned above, did not strictly conform to the mandate of Rule 2BA of the Income Tax Rules. The latter statutory provision clearly enumerates the conditions necessary for a Voluntary Retirement Scheme to qualify for the benefits envisaged under Section 10(10C) of the Income Tax Act. The distinguishing features in the E.O.S formulated by the State Bank of Travancore, which did not render it in conformity with the requirements of Rule 2BA of the Income Tax Rules, have been clearly brought out in the order of the Assessing Authority and read as follows: "i) The objective of the "EOS" (Clause 1) was to provide an exit route to eligible officers in the from Top Executive Grade Special Scale II to Junior Management Grade Scale I to whom the State bank of Travancore (Officers') service Rules are applicable who feel frustrated and demotivated due to lack of career prospects. It is to be noted that the scheme was applicable to only those officers who feel frustrated and demotivated due to lack of promotion and not to all officers in the categories stated above (not to mention 'all employees). As per the requirement (i) prescribed in Rule 2BA the V R scheme should apply to all employees, by whatever name called including workers and executives. (ii) The eligibility criteria specified in the "EOS" (clause 2) were officers who are over 45 years and below 58 years of age as on the date of application and (only) who have not been promoted to the next higher Grade/Scale after availing one chance and were also superseded by their juniors. As per requirement (ii) prescribed in Rule 2BA all employees who have completed 40 years of age or has completed 10 years of service are eligible for V R S. Thus the eligibility criteria fixed in the "EOS" is markedly different and is not in consonance with the guidelines prescribed under Rule 2B?. (iii) The ex gratia payable under "EOS" (Clause 4) was salary last drawn for 50% of service remaining up to the age of 60 years as on the date of exit from bank. This is also not in consonance with the guideline/requirement (vi) regarding the amount receivable on account of voluntary retirement stipulated as 'not exceeding the amount equivalent to three months salary for each completed year of service or salary at the time of retirement multiplied by the balance months of service left before the date of retirement on superannuation'. (v) As per Clause 12(ii) of the "EOS", an officer who exercises the Exit Option shall not be precluded from taking up assignments in State Bank of India / Other Associates / Subsidiaries / Joint Ventures of the Bank (including office outside India) This clause is in gross violation of the guideline / requirement (v) prescribed in Rule 2BA stipulating that the retiring employee of a company shall not be employed in another company or concern belonging to the same management. (vi) As per requirement (iii) prescribed under Rule 2BA, the scheme of voluntary retirement or voluntary separation has to be drawn to result in overall reduction in the existing strength of the employees and requirement / guideline (iv) stipulates that the vacancy caused by the voluntary retirement or voluntary separation is not to be filled up. (vi) As per requirement (iii) prescribed under Rule 2BA, the scheme of voluntary retirement or voluntary separation has to be drawn to result in overall reduction in the existing strength of the employees and requirement / guideline (iv) stipulates that the vacancy caused by the voluntary retirement or voluntary separation is not to be filled up. Clauses to these effect are not seen incorporated in the "EOS' formulated by M/s State Bank of Travancore." 7.It was on account of the features of the E.O.S described above, that did not render it in conformity with the requirement of Rule 2BA, that the Assessing Officer, the First Appellate Authority, and thereafter, the Appellate Tribunal held against the assessee in relation to her claim for an exemption under Section 10 (10C) of the Income Tax Act. Even before us in this appeal, there is nothing produced that would suggest that the concurrent findings of fact by the authorities below were perverse or based on no evidence whatsoever. Under such circumstances, we find that there is no substantial question of law that arises for consideration in this appeal since the findings of all the authorities have been essentially on the facts that obtained in the instant case. We therefore see no reason to interfere with the impugned order of the Appellate Tribunal. This Income Tax Appeal fails and is dismissed by finding that no substantial question of law arises for consideration in the instant appeal.