Appreciation of evidence in cash source dispute: HC found no substantial question of law and declined interference.

The dispute concerned whether cash found with the assessee represented sale proceeds of gold and whether the explanation offered was acceptable. The HC held that the authorities below had relied on material on record, including statements of examined persons and other evidence, and that the finding rejecting the assessee's explanation was plausible and not perverse. As the matter turned on appreciation of evidence rather than any debatable legal issue, no substantial question of law arose for interference.

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Issues: Whether any substantial question of law arose from the findings that the cash of Rs. 30,00,000 found with the assessee represented sale proceeds of gold and that the assessee's explanation was unacceptable.

Analysis: The finding of the authorities below was based on the material on record, including statements of examined persons and other evidence. The conclusion that the assessee's explanation was not worthy of acceptance was treated as plausible and not perverse. The dispute was held to turn on appreciation of evidence rather than on any legal issue warranting interference.

Conclusion: No substantial question of law arose for consideration, and the assessee's challenge failed.

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