Concurrent findings of fact on loan genuineness, receipts and expenses left undisturbed; no substantial question of law arose.

Concurrent factual findings on the assessee's unsecured loan, receipts and expense disallowances were upheld because identity, bank records, income-tax particulars, source explanation, interest payment and tax deduction at source supported the loan, service tax and escort charges were separately recorded with only a minor unexplained difference, and the vouchers and business explanation justified the expenses. The Rule 46A objection was rejected, and the appellate authorities' conclusions were treated as findings of fact. No substantial question of law arose, so no interference was warranted in second appeal.

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Issues: Whether the Tribunal's order deleting additions and disallowances, and the challenge based on Rule 46A, gave rise to any substantial question of law warranting interference in appeal.

Analysis: The assessee's unsecured loan was accepted on the basis of identity, bank records, income-tax particulars, source explanation, payment of interest and deduction of tax at source, and the authorities below recorded that the onus under section 68 had been discharged. On the receipts issue, the appellate authorities found that service tax and escort charges had been separately reflected and that only a small unexplained difference remained. On the disallowance of expenses, the first appellate authority and the Tribunal accepted the supporting vouchers and business explanation and held that ad hoc disallowance was not justified. The challenge that the relief was granted in violation of Rule 46A was not accepted, and the findings were treated as concurrent findings of fact.

Conclusion: No substantial question of law arose, and the appeal was dismissed.

Final Conclusion: The appellate findings on credit entries, receipts and expenses were left undisturbed, with no interference warranted in second appeal.

Ratio Decidendi: When the lower appellate authorities return concurrent factual findings on genuineness, creditworthiness and reconciliation of accounts, no substantial question of law arises unless a clear legal error or procedural violation is shown.

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