Factual findings on books of account and stock valuation left no substantial question of law under income-tax appeal.

The Tribunal's deletion of the addition made after rejection of the books of account was upheld because the Assessing Officer pointed out no specific defect in the books, the closing stock valuation was not shown to be infirm, and the assessee had followed a consistent method of accounting and stock valuation. The High Court treated the Tribunal's conclusion as a factual determination based on the record and found no perversity. As the dispute did not give rise to any substantial question of law under Section 260A of the Income-tax Act, 1961, the Revenue's challenge failed and the addition was not revived.

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Issues: Whether the Tribunal was justified in upholding the deletion of the addition made by rejecting the books of account and applying a gross profit rate, and whether any substantial question of law arose in the appeal under Section 260A of the Income-tax Act, 1961.

Analysis: The findings of the Tribunal and the first appellate authority were based on appreciation of the material on record. The Assessing Officer had not pointed out any specific defect in the books, the valuation of closing stock had not been shown to be infirm, and the assessee had followed a consistent method of accounting and stock valuation. The conclusion reached by the Tribunal was therefore treated as a factual determination, not shown to be perverse. In such circumstances, no substantial question of law arose for consideration.

Conclusion: The addition made by rejecting the books of account was not revived, and the Revenue's challenge failed.

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