Factual findings under Section 260A defeated the tax appeal where the Tribunal deleted additions on unreliable evidence.

An appeal under Section 260A of the Income-tax Act, 1961 did not raise a substantial question of law where the Tribunal's deletion of additions rested on factual appreciation of evidence. The Tribunal found that the Revenue's relied agreement was not duly signed by the company, the alleged receipt of Rs. 70 lakhs was not proved by reliable evidence, and the material was only presumptive; it also held that the commission addition could not survive once the underlying transaction had already been consistently dealt with and the factual basis for the addition had failed. The HC treated these conclusions as findings of fact and declined to interfere, leaving the Tribunal's deletions undisturbed.

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Issues: Whether the appeal under Section 260A of the Income-tax Act, 1961 raised any substantial question of law when the Tribunal had deleted the additions on the basis of its factual appreciation of the evidence.

Analysis: The Tribunal had found that the agreement relied upon by the Revenue was not duly signed by the company, that the alleged receipt of Rs. 70 lakhs was not proved by reliable evidence, and that the material relied upon by the authorities below was presumptive. It also held that the enhancement on account of commission could not stand once the same transaction had already been dealt with consistently and the factual premise for the addition had failed. The High Court found that these conclusions turned essentially on appreciation of facts and did not give rise to any substantial question of law for consideration under Section 260A.

Conclusion: No substantial question of law arose, and the additions deleted by the Tribunal were not disturbed.

Ratio Decidendi: An appeal under Section 260A of the Income-tax Act, 1961 does not lie on pure findings of fact unless a substantial question of law arises from those findings.

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