Section 260A appeal on alleged suppressed transactions failed because the findings were treated as purely factual.

The Delhi HC noted that an appeal under Section 260A of the Income-tax Act requires a substantial question of law, but the challenge in this matter concerned findings on alleged suppression of transactions. The Tribunal had examined seized books, supplier material, certificates and correspondence, and agreed with the CIT(A) that the assessee's explanation was inconsistent and that the suppression finding was justified on the facts. As the conclusions depended on appreciation of evidence, direct sales, commission receipts and running accounts, the Court treated the issue as purely factual and held that no substantial question of law arose, so the appeal was not maintainable.

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Issues: Whether the appeal under Section 260A of the Income-tax Act, 1961 raised any substantial question of law where the Tribunal had upheld findings on alleged suppression of transactions.

Analysis: The dispute turned on whether the assessee had established that the alleged suppressed transactions were only direct sales to customers and that it merely received commission. The lower authorities relied on seized books of account, the supplier's report, certificates and correspondence, and found that the assessee's stand varied at different stages. The Tribunal examined the factual material, including the running accounts and the explanation regarding direct purchases, and concurred with the Commissioner of Income-tax (Appeals) that the suppression finding was justified. The Court found these conclusions to be purely factual and not giving rise to any question of law.

Conclusion: No substantial question of law arose; the appeal was not maintainable.

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