Concurrent findings of fact barred interference, as no substantial question of law arose in the cash deposit dispute.

Concurrent findings that cash deposits, alleged advances against sale agreements, and undisclosed interest were not satisfactorily explained were based on appreciation of evidence at all three stages. The High Court held that the authorities had taken a probable view on the facts, with no perversity or arguable legal issue shown. As the challenge did not raise any substantial question of law, the additions were not interfered with and the appeal failed at the threshold.

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Issues: Whether the appeal under Section 260-A of the Income-tax Act, 1961 raised any substantial question of law when the additions were sustained on concurrent findings of fact.

Analysis: The assessee's explanation for cash deposits was rejected at all three levels on the basis of appreciation of evidence. The authorities found that the alleged advances against sale agreements were not proved to be genuine, the identity and availability of some alleged payers was not established, and the creditworthiness of the persons who allegedly advanced cash was not satisfactorily shown. The explanation for the further cash deposit and undisclosed interest was also disbelieved on facts. The Court found that these were purely factual determinations, that the view taken by the authorities was a probable view, and that no perversity or legal issue warranting interference was shown.

Conclusion: No substantial question of law arose. The additions sustained by the lower authorities were not interfered with.

Final Conclusion: The appeal failed at the threshold because the challenged findings were concurrent findings of fact, and the High Court declined to reopen them in the absence of perversity or any arguable legal question.

Ratio Decidendi: Concurrent factual findings, if probable and untainted by perversity, do not give rise to a substantial question of law in an appeal under Section 260-A of the Income-tax Act, 1961.

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