Purely factual findings on unsecured loans and commission claims raise no substantial question of law under income-tax appeal

The High Court held that the Tribunal's deletion of additions relating to unsecured loans, commission/discount, and connected disallowances raised no substantial question of law under Section 260A. The Tribunal had relied on confirmations, vouchers, commission and discount details, and the Revenue's failure to effectively rebut that evidence. As those findings were purely factual and were not shown to be perverse, the appeal did not justify interference. The deleted additions were therefore sustained in favour of the assessee.

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Issues: Whether the Tribunal's deletion of additions on account of unsecured loans, commission/discount, and related disallowances gave rise to any substantial question of law under Section 260A of the Income-tax Act, 1961.

Analysis: The Tribunal's conclusions were based on appreciation of evidence, including confirmations, vouchers, details of commission and discount, and the absence of any effective rebuttal by the Revenue. The High Court found that the challenged findings were purely factual, were not shown to be perverse, and therefore did not warrant interference in an appeal under Section 260A, which lies only on substantial questions of law.

Conclusion: No substantial question of law arose. The additions deleted by the Tribunal were sustained in favour of the assessee.

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