Search document presumption supports tax addition; concurrent factual findings blocked appellate interference absent perversity.

Seized search documents containing month-wise interest workings were treated as reliable material, and the statutory presumption attached to such documents supported inference of an actual transaction, including principal and interest. The assessee's claim that the papers were only rough workings was rejected on the facts. Concurrent findings of the lower authorities, being based on evidence and not shown to be perverse or unsupported, did not raise any substantial question of law for appellate interference. The additions based on the seized document were therefore sustained, and the appellate challenge failed.

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Issues: (i) Whether the document recovered in the search attracted the statutory presumption and justified addition of the principal amount and interest, and (ii) whether the concurrent factual findings of the lower authorities gave rise to any substantial question of law warranting interference under section 260A.

Issue (i): Whether the document recovered in the search attracted the statutory presumption and justified addition of the principal amount and interest.

Analysis: The seized papers were found during search and contained a typed month-wise working of interest on a principal sum. The assessee's explanation that the papers were merely rough working was not accepted by the fact-finding authorities. The materials were treated as reliable search material, and the statutory presumption applicable to such documents supported the inference that the entries reflected an actual transaction.

Conclusion: The issue was decided against the assessee and in favour of the Revenue.

Issue (ii): Whether the concurrent factual findings of the lower authorities gave rise to any substantial question of law warranting interference under section 260A.

Analysis: The findings were based on appreciation of the evidence and were not shown to be perverse or based on no evidence. In appellate jurisdiction under section 260A, interference is not justified merely because another view is possible when the conclusion reached is a reasonable one on the record.

Conclusion: No substantial question of law arose, and the appellate challenge failed.

Final Conclusion: The additions made on the basis of the seized document were sustained, and the appeal was summarily rejected with all connected appeals meeting the same fate.

Ratio Decidendi: Where search material is supported by a statutory presumption and the concurrent factual findings are neither perverse nor unsupported by evidence, no substantial question of law arises for interference in appeal.

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