Reassessment reopening based on seized cash receipts stayed factual, so no substantial question of law arose in appeal.

Challenge to reassessment reopening under section 147 on the basis of seized material was discussed in terms of whether it raised any substantial question of law under section 260A. The reasons recorded referred to a belief that income had escaped assessment because of cash receipts outside the books. The determination that such receipts existed was treated as a factual finding reached by the appellate authorities on the material before them, and no legal infirmity in those findings was identified for appellate interference. On that basis, no substantial question of law was said to arise, and the challenge to the reopening and additions was stated to fail.

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Issues: Whether, on the facts, the challenge to reopening of assessment under section 147 and the resulting additions gave rise to any substantial question of law under section 260A.

Analysis: The recorded reasons for reopening showed a belief that income chargeable to tax had escaped assessment on the basis of seized material indicating cash receipts outside the books. The findings on the existence of receipts beyond the books were factual findings arrived at by the appellate authorities after considering the relevant material. Such factual determinations did not disclose any legal infirmity warranting interference in an appeal under section 260A.

Conclusion: No substantial question of law arose, and the challenge to the reopening and additions failed.

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