No substantial question of arises in case where ITAT remands an issue to the file of CIT(A) for fresh consideration:

The Hon’ble ITAT remanded the issue as regardsdisallowance u/s 14A to the file of CIT(A). On Revenue’s appeal, the Hon’ble High Court found that ITAT had merely remanded the issue to the file of CIT(A)for fresh consideration in light of the applicable law and judgments in the field. It was held that no substantial question of arises out of the same and the tax appeal was dismissed.

[ZEPPELIN MOBILE SYSTEMS (INDIA) LTD. - TAX APPEAL No.1212 of 2011 - GHC]