Substantial Question of Law absent where partners' capital credits were supported by factual findings and taxed in individual hands.

In an appeal under section 260A, interference was not justified because the challenge did not raise any substantial question of law. The partners had credited sums to their capital accounts from stated individual sources, and the appellate authorities found as a matter of fact that the partners had already declared the income in their own hands and paid tax on it. There was no concrete evidence of concealed income or any discrepancy attributable to the firm, and no material showed the factual finding to be perverse or unsupported by evidence. The addition in the firm's hands was therefore not sustained.

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Issues: Whether the Revenue's appeal under section 260A of the Income-tax Act, 1961 disclosed any substantial question of law in respect of addition made in the firm's hands on account of credits in the partners' capital accounts.

Analysis: The partners had credited amounts to their capital accounts and had stated that the funds came from their individual sources. The appellate authorities found, as a matter of fact, that the partners had declared the income in their individual capacity, paid tax thereon, and that there was no concrete evidence of concealed income or any discrepancy attributable to the firm. In an appeal under section 260A, interference is warranted only where a substantial question of law arises. The finding recorded below was a factual finding, and no material was shown to demonstrate that it was perverse or unsupported by evidence.

Conclusion: No substantial question of law arose. The addition in the hands of the assessee-firm was not sustained.

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