Substantial Question of Law absent where Tribunal's reasoned findings on will genuineness and asset ownership were not perverse.

In an appeal under section 260A of the Income-tax Act, the High Court held that concurrent factual findings on the genuineness of the will and ownership of assets did not give rise to any substantial question of law. The Tribunal had examined the evidence, accepted that the deceased had independent income, rejected the allegation that assets in family members' names were benami holdings of the assessee, and relied on probate of the will as supporting ownership in the deceased. As no perversity in those findings was shown, interference was unwarranted and the Tribunal's conclusions were left undisturbed.

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Issues: Whether the Tribunal's factual findings regarding the genuineness of the will and ownership of the assets gave rise to any substantial question of law under section 260A of the Income-tax Act, 1961.

Analysis: The Tribunal had examined the evidence in detail and recorded findings that the late L. P. Khanna had independent sources of income, that the assets standing in the names of the family members were not held benami by the assessee, and that the probate of the will supported the claim that the properties belonged to the deceased. In an appeal under section 260A, interference is warranted only where a substantial question of law arises, and concurrent or reasoned factual findings cannot be disturbed unless shown to be perverse. The Court found that the controversy essentially turned on appreciation of facts and that no perversity in the Tribunal's conclusions was established.

Conclusion: No substantial question of law arose, and the Tribunal's factual findings were not liable to be interfered with.

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