Fair market value valuation findings are factual in Chapter XX-A appeals, limiting High Court interference to errors of law.

In an appeal under section 269H of the Income-tax Act, the High Court's jurisdiction was confined to questions of law, so it could not interfere with the Tribunal's valuation finding unless an error of law was shown. The Tribunal had reappreciated the evidence, applied the comparable sales method, and reached its own conclusion on fair market value in proceedings for acquisition of immovable property under Chapter XX-A. That determination was treated as a factual finding, not a legal error, and the High Court upheld it without interference.

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Issues: Whether the Tribunal's determination of the fair market value of the property was lawful and valid, and whether the High Court could interfere with that determination under its limited jurisdiction.

Analysis: The appeal arose from proceedings under Chapter XX-A of the Income-tax Act, 1961 concerning acquisition of immovable property on the footing that the fair market value exceeded the apparent consideration. The Tribunal had jurisdiction to reappreciate the evidence and reach its own conclusion on valuation. It examined the material on record, applied the comparable sales method of valuation, and, on that basis, differed from the Inspecting Assistant Commissioner. The High Court held that the Tribunal's conclusion was one of fact and did not disclose any error of law. In an appeal under section 269H, interference was confined to questions of law, not pure findings of fact.

Conclusion: The Tribunal's valuation finding was upheld and no interference was called for.

Ratio Decidendi: In an appeal under section 269H of the Income-tax Act, 1961, the High Court cannot interfere with a Tribunal's valuation finding unless it discloses an error of law; a reasoned reappreciation of evidence on fair market value is a question of fact.

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