Section 260A limits interference with factual findings where rejection of accounts and best judgment assessment rest on evidence.

Under section 260A of the Income-tax Act, the High Court can interfere only on a substantial question of law, not with Tribunal findings based on appreciation of evidence. The Tribunal's conclusion that the assessee had not maintained quantitative details of sarees, that the alleged purchases were not verifiable and could be treated as bogus, and that rejection of accounts justified a best judgment assessment were all factual determinations. Once accounts are rejected, best judgment assessment is permissible and involves an element of guesswork. Those factual findings were therefore not open to interference under section 260A, and the appeal failed.

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Issues: Whether the High Court could interfere under section 260A of the Income-tax Act, 1961 with the Tribunal's factual findings upholding rejection of accounts and the conclusion that the purchases were not verifiable and could be treated as bogus.

Analysis: The appeal under section 260A lies only on a substantial question of law. The Tribunal's view that the assessee had not maintained quantitative details of sarees of different lengths and that the claimed purchases could be bogus was based on appreciation of evidence and factual inference. The correctness of the saree length, the verifiability of purchases, and the propriety of the best judgment assessment were all matters of fact. Once the accounts were rejected, a best judgment assessment was permissible, and such assessment necessarily involves an element of guesswork.

Conclusion: The factual findings of the Tribunal were not open to interference under section 260A, and the appeal failed.

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