Section 11 exemption sustained on concurrent factual findings; no substantial question of law arose in appeal.

Section 11 exemption was sustained because the audit report under section 12A(b) had been submitted and was on record before the appellate authority. The Commissioner (Appeals) and the Tribunal recorded concurrent findings that there was no infirmity in the first appellate order, and those factual findings were not challenged by the Revenue. On that basis, the Court treated the issue as one of fact, held that no substantial question of law arose under section 260A, and the appeal failed.

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Issues: Whether the assessee was entitled to exemption under section 11 of the Income-tax Act, 1961 in view of the audit report under section 12A(b), and whether any substantial question of law arose from the Tribunal's order.

Analysis: The Commissioner (Appeals) found as a fact that the audit report had been submitted and produced before the appellate authority. The Tribunal affirmed that finding and held that the record disclosed no infirmity in the first appellate order. The Revenue did not challenge those factual findings, and the Court treated them as pure findings of fact. In such circumstances, no substantial question of law arose from the Tribunal's order under section 260A.

Conclusion: The exemption under section 11 was upheld on the basis of concurrent findings of fact, and the appeal failed for want of any substantial question of law.

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