Concurrent factual findings in block assessment upheld; no substantial question of law arose in the revenue's appeal.

In a block assessment under Chapter XIV-B, the HC treated the Tribunal's view as factual where seized material was examined alongside regular books and audited accounts, and most entries were already reflected in the assessee's records. Only a limited unexplained amount was found to represent undisclosed income, and the remaining additions were held to be matters of fact. As the revenue challenge did not raise any substantial question of law under section 260-A, the HC declined to interfere and upheld the Tribunal's factual conclusions.

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Issues: Whether the Tribunal's findings that only a small part of the material found during search represented undisclosed income, and that the remaining additions were matters of fact not giving rise to any substantial question of law under the appellate jurisdiction, were sustainable.

Analysis: The search assessment was examined in the context of Chapter XIV-B of the Income-tax Act, 1961. The Court noted that undisclosed income for the block period must be computed on the basis of evidence found as a result of search, and that the Tribunal had considered the seized register along with the regular books and audited accounts maintained by the assessee. The Tribunal had recorded concurrent findings that most entries in the seized material were already reflected in the regular records and that only a limited amount remained unexplained. Those findings were treated as findings of fact. The Court held that the revenue's challenge did not disclose any substantial question of law.

Conclusion: The Tribunal's factual conclusions were upheld, and the revenue's appeal was not entertained on merits.

Final Conclusion: The appellate court declined to interfere with the Tribunal's view that the disputed additions were factual and that only the unexplained amount could be treated as undisclosed income, leaving no substantial question of law for decision.

Ratio Decidendi: Concurrent factual findings on the basis of seized material and regular books, if not shown to be perverse or to raise a substantial question of law, do not warrant interference in an appeal under section 260-A.

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