Pure findings of fact on land valuation under capital gains law were not open to interference in second appeal.

Factual findings on the undeveloped nature of land, absence of civic amenities, and persistence of agricultural use could not be interfered with in a section 260A appeal because they were pure findings of fact. The Tribunal had assessed the evidence and fixed the land's market value as on 1 April 1981 for capital gains computation under section 48; that valuation was treated as a generous factual assessment, not a legal error. Accordingly, the challenge to the computation of capital gains failed because no question of law arose for appellate interference.

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Issues: Whether the Tribunal's findings on the undeveloped nature of the locality, absence of civic amenities, and the market value of the land as on 1 April 1981 could be interfered with in an appeal under section 260A of the Income-tax Act, 1961.

Analysis: The Tribunal had, on a detailed appraisal of the evidence, found that the land was not in a developed area in 1981, had no surrounding development or civic amenities, and remained agricultural for many years thereafter. These determinations were pure findings of fact. In an appeal under section 260A, such factual conclusions could not be reappreciated in the absence of any legal error. The Tribunal's fixation of the market value at the maximum rate of Rs. 1,00,000 per acre for computation of capital gains under section 48 was also treated as a generous assessment on the facts found.

Conclusion: The factual findings of the Tribunal were not open to interference and the challenge to the computation of capital gains failed.

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