Tribunal's factual appreciation upheld where no perversity or record inconsistency was shown in deleting assessment additions.

The Tribunal's order was examined on the question whether it was vitiated by ignoring relevant evidence or by a wrong appreciation of facts. The appellate authorities had considered the assessment under section 143(3) read with section 251 on the material on record, the Commissioner (Appeals) deleted the Assessing Officer's additions, and the Tribunal upheld that view on a consolidated assessment of the facts. No legal infirmity, perversity, or inconsistency with the record was shown in the Tribunal's approach, and the questions were answered against the Revenue and in favour of the assessee.

---

---

Issues: Whether the Tribunal's order was vitiated for ignoring relevant and admissible evidence and for being based on a wrong appreciation of facts and evidence.

Analysis: The assessment under section 143(3) of the Income-tax Act, 1961, read with section 251, had been examined by the appellate authorities on the material on record. The additions made by the Assessing Officer were deleted by the Commissioner of Income-tax (Appeals), and the Tribunal, on a consolidated consideration of the facts, upheld that view. No legal infirmity, perversity, or inconsistency with the record was shown in the Tribunal's approach.

Conclusion: The questions were answered against the Revenue and in favour of the assessee.

---