Substantial question of law absent where block assessment findings were factual and based on seized material and evidence.

The Tribunal's findings in a block assessment were held to rest on appreciation of seized material, the assessee's explanation and surrounding evidence, so they were treated as findings of fact. As no perversity or legal infirmity was shown, no substantial question of law arose for interference under section 260A of the Income-tax Act, 1961. The appeal was therefore not maintainable on the merits of the factual conclusions, and the assessee succeeded.

---

---

Issues: Whether the Tribunal's findings in the block assessment gave rise to any substantial question of law warranting interference under section 260A of the Income-tax Act, 1961.

Analysis: The additions in dispute arose from seized material and the Tribunal evaluated the document, the assessee's explanation, and the surrounding evidence. The Court found that the Tribunal's conclusions were based on appreciation of evidence and were findings of fact. No perversity or legal infirmity was shown to justify interference in appeal under section 260A.

Conclusion: No substantial question of law arose. The appeal was not maintainable on the merits of the factual findings and the assessee succeeded.

---