Concurrent factual findings on share-sale valuation did not raise a substantial question of law under Section 260A.

Concurrent factual findings on the assessee's share-sale rate were upheld because the Tribunal and CIT(A) had accepted the market quotation evidence and found no brokerage payment. The High Court held that the dispute turned on appreciation of evidence and factual inference, not on any legal principle or statutory interpretation. As no legal infirmity was shown in the concurrent findings, no substantial question of law arose under Section 260A of the Income-tax Act, 1961, and the Revenue's challenge failed.

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Issues: Whether the Revenue had raised any substantial question of law against the Tribunal's affirmation of the assessee's share-sale rate for the purpose of computing the assessed loss.

Analysis: The Tribunal had given reasons for accepting the rate adopted by the CIT(A), holding that the actual sale price of Rs.88 per share represented the lowest quoted market rate prevailing on the relevant day and that no sale brokerage had been paid. The dispute turned on appreciation of evidence and factual inference from the market quotations. In such a situation, the High Court found no error in the concurrent factual finding and no legal issue warranting interference under Section 260A.

Conclusion: No substantial question of law arose and the Revenue's challenge failed.

Final Conclusion: The factual finding adopting Rs.88 per share was sustained, and the appeal was rejected.

Ratio Decidendi: Concurrent findings based on appreciation of evidence, without any legal infirmity, do not give rise to a substantial question of law under Section 260A of the Income-tax Act, 1961.

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