No substantial question of law arises where block assessment additions rest on search material and factual findings remain unassailable.

In an appeal under section 260A of the Income-tax Act, the High Court will not interfere with concurrent factual findings or estimations merely because another view is possible; interference lies only if the findings are perverse or impossible. Additions sustained in block assessment based on incriminating material recovered during search and the assessee's unreliable books were treated as pure findings of fact. As no substantial question of law arose from the Tribunal's conclusions, the factual findings remained undisturbed and the appeal failed.

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Issues: Whether the Tribunal's findings sustaining additions in block assessment, based on incriminating material recovered during search, gave rise to any substantial question of law under section 260A of the Income-tax Act, 1961.

Analysis: The additions were upheld on the basis of material recovered in search under section 132 of the Income-tax Act, 1961. The assessee's books of account were found unreliable and the assessment rested on the search material and related estimation. The Court held that the Tribunal's conclusions were pure findings of fact. In an appeal under section 260A, interference is not warranted merely because another estimate may be possible, unless the Tribunal's estimate is shown to be impossible.

Conclusion: No substantial question of law arose, and the Tribunal's factual findings were not open to interference.

Final Conclusion: The additions sustained in block assessment remained undisturbed and the appeal failed.

Ratio Decidendi: In an appeal under section 260A of the Income-tax Act, 1961, the High Court does not interfere with concurrent factual findings or estimations based on search material unless those findings are shown to be perverse or impossible.

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