Unexplained cash credits and unsupported agricultural income claims were treated as factual issues, with no substantial question of law found.

Concurrent findings that cash deposits claimed as agricultural income lacked credible documentary support, and that interest credited in a recurring deposit account was not shown by material evidence to relate to earlier years, were treated as factual determinations. The Tribunal upheld the additions under section 68 of the Income-tax Act, 1961, because the assessee failed to maintain proper accounts and did not discharge the burden of explaining the credits. On section 260A review, the High Court held that the issues raised were essentially factual and did not give rise to any substantial question of law, so the additions were not interfered with.

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Issues: Whether the additions sustained by the appellate authorities under section 68 of the Income-tax Act, 1961, and the rejection of the claim of agricultural income and interest income, gave rise to any substantial question of law warranting interference under section 260A of the Income-tax Act, 1961.

Analysis: The concurrent authorities found that the assessee failed to produce credible documentary evidence to substantiate the source of cash deposits claimed as agricultural income, and also failed to establish, by material evidence, that the interest credited in the recurring deposit account related to earlier years. The Tribunal affirmed the assessment on the basis of absence of proof, non-maintenance of proper accounts, and failure to discharge the burden of explaining the impugned credits. The High Court treated these findings as concurrent findings of fact and held that the questions raised were essentially factual, not substantial questions of law.

Conclusion: No substantial question of law arose, and the additions sustained by the Tribunal were not interfered with.

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