Substantial question of law absent where income-tax dispute turned only on factual valuation of zip fasteners

An appeal under Section 260A of the Income-tax Act was found not entertainable because the dispute concerned only the valuation of zip fasteners, which turned on facts, material and evidence. The Commissioner (Appeals) and the Tribunal had reached concurrent findings that were reasonable and not perverse. As the challenge attacked only factual appreciation and did not raise any substantial question of law, interference in second appeal was unwarranted.

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Issues: Whether the appeal under Section 260A of the Income-tax Act, 1961 disclosed any substantial question of law in view of the factual dispute regarding valuation of zip fasteners.

Analysis: The dispute related only to the valuation of zip fasteners adopted by the Assessing Officer and modified by the appellate authorities on the basis of facts, material and evidence. The concurrent findings of the Commissioner (Appeals) and the Tribunal were found to be reasonable and not perverse. Since the challenge did not raise a legal question but only assailed factual appreciation, interference in an appeal under Section 260A was not warranted.

Conclusion: The appeal did not involve any substantial question of law and was not entertainable under Section 260A of the Income-tax Act, 1961.

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