Substantial question of law not made out in reassessment dispute based on concurrent factual findings and valuation material.

Concurrent factual findings in reassessment proceedings under sections 147 and 148 were upheld after the appellate authorities appreciated the evidence, including search material and valuation material. The HC found no infirmity in those findings and no basis to treat the matter as raising a substantial question of law. On that footing, the challenge to the Tribunal's order was rejected.

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Issues: Whether any substantial question of law arose from the Tribunal's order in the reassessment proceedings under sections 147 and 148 of the Income-tax Act, 1961, in the background of the search under section 132 and the valuation material relied upon.

Analysis: The appellate authorities had returned concurrent findings of fact after appreciating the evidence on record. The order under challenge did not disclose any infirmity in those findings, and no basis was made out to treat the matter as raising a substantial question of law.

Conclusion: No substantial question of law arose, and the challenge to the Tribunal's order was rejected.

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