Concurrent factual findings on stock shortage did not raise a substantial question of law, so the addition stayed deleted.

Concurrent factual findings that no discrepancy in the books or evidence of unrecorded sales had been established will not attract interference under section 260A unless they are shown to be perverse. The appellate authorities accepted the assessee's explanation for the stock shortage during survey as plausible in the trade context and deleted the addition. The High Court held that the Revenue's challenge was directed only at factual conclusions that were sustainable on the record, so no substantial question of law arose and the deletion was upheld.

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Issues: Whether the addition made on account of stock shortage detected during survey was rightly deleted and whether the findings of the appellate authorities gave rise to a substantial question of law under section 260A.

Analysis: The addition rested on a discrepancy between the statement recorded during survey and the explanation offered in assessment proceedings. The appellate authorities found that no discrepancy in the books of account or evidence of sales outside the books had been established, and treated the explanation regarding custody of ornaments as plausible in the trade context. Their concurrent findings were based on appreciation of facts and were not shown to be perverse. In an appeal under section 260A, interference is warranted only when a substantial question of law arises, and a mere challenge to factual conclusions that are plausible does not satisfy that standard.

Conclusion: The deletion of the addition was upheld and no substantial question of law arose; the issue was decided against the Revenue and in favour of the assessee.

Final Conclusion: The appeal failed because the concurrent factual findings were found to be sustainable and outside the scope of interference under section 260A.

Ratio Decidendi: Under section 260A of the Income-tax Act, 1961, concurrent factual findings that are plausible and not perverse do not give rise to a substantial question of law.

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