Substantial question of law requirement bars reopening factual findings on unexplained cash deposits in income-tax appeal.

An appeal under Section 260A of the Income-tax Act, 1961 lies only where a substantial question of law arises. The Court found that the challenge concerned the assessee's explanation for cash deposits in the bank account and the correctness of factual findings by the lower authorities. Because the explanation was unsupported by cogent evidence, the issue remained purely factual and no perversity in the findings was shown. As no debatable or unsettled question of law arose, the appeal was not maintainable on merits and the dismissal of the assessee's challenge was confirmed.

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Issues: Whether the appeal under Section 260A of the Income-tax Act, 1961 disclosed any substantial question of law so as to warrant interference with the Tribunal's dismissal of the assessee's appeal.

Analysis: The appeal under Section 260A lies only where a substantial question of law arises. The challenge before the Court turned on the sufficiency of the explanation for cash deposits in the assessee's bank account and the correctness of the factual findings recorded by the appellate authorities. The Court held that the explanation for the deposits was unsupported by cogent evidence and that the issue was essentially factual. No perversity in the findings was shown, and no debatable or unsettled question of law arose from the record.

Conclusion: No substantial question of law arose for consideration under Section 260A of the Income-tax Act, 1961. The appeal was therefore not maintainable on merits and failed.

Final Conclusion: The assessee's challenge to the Tribunal's order could not be entertained, and the dismissal of the appeal stood confirmed.

Ratio Decidendi: An appeal under Section 260A of the Income-tax Act, 1961 is maintainable only when the case gives rise to a substantial question of law, and pure findings of fact on the adequacy of evidence cannot be reopened unless shown to be perverse.

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