Substantial Question of Law absent where Tribunal's factual findings on purchases and credits were not shown to be perverse.

In an appeal under section 260-A of the Income-tax Act, the HC held that no substantial question of law arose because the Tribunal's deletion of additions rested on detailed factual findings regarding the genuineness of purchases, credits and cash credit entries. After examining books, confirmations, bank records, bills and stock registers, the Tribunal had accepted the assessee's case as a matter of fact. The Court found no perversity in those findings and treated the departmental grievances as pure questions of fact, so the additions deleted by the Tribunal were not interfered with.

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Issues: Whether the appeal under section 260-A of the Income-tax Act, 1961 raised any substantial question of law, and whether the Tribunal's deletion of additions based on appreciation of facts called for interference.

Analysis: The appeal challenged the Tribunal's deletion of additions relating to unaccounted investment, purchase transactions, and cash credit. The Court held that the Tribunal had recorded detailed factual findings after examining the books, confirmations, bank records, bills, stock registers, and other material. The controversy turned on genuineness of purchases, credits, and the correctness of factual appreciation by the Tribunal, which functions as the final fact-finding authority. The Court found that the departmental questions were in substance only questions of fact, that no perversity was shown in the Tribunal's findings, and that the settled tests for a substantial question of law were not satisfied.

Conclusion: No substantial question of law arose. The Tribunal's factual findings were upheld and the additions deleted by it were not interfered with.

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