Substantial question of law absent where concurrent findings supported Section 54F deduction for residential investment

Under Section 260A of the Income-tax Act, the High Court will interfere only if the Revenue raises a substantial question of law. Here, the Tribunal and appellate authority had recorded concurrent findings that the assessee invested the capital gains in land purchase and construction of a residential house, bringing the claim within Section 54F. As those findings were based on the factual record and were neither perverse nor unsupported by evidence, no substantial question of law arose. The Revenue's challenge to the deduction was therefore not entertained, and the assessee succeeded.

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Issues: (i) Whether the Revenue's appeal under Section 260A of the Income-tax Act, 1961 raised any substantial question of law so as to warrant interference with the concurrent factual findings that the assessee was entitled to deduction under Section 54F.

Analysis: The appeal lay only on a substantial question of law. The Tribunal and the appellate authority had both recorded concurrent findings that the assessee had invested the capital gain in purchase of land and construction of a residential house within the statutory framework, and that the factual materials did not justify denial of the claim. The Court reiterated that the right of appeal under Section 260A is limited and that concurrent findings of fact are not to be disturbed unless they are shown to be perverse, based on no evidence, or vitiated by a legal error in applying settled principles.

Conclusion: No substantial question of law arose. The Revenue's challenge to the allowance of deduction under Section 54F was not entertained, and the assessee succeeded.

Ratio Decidendi: In an appeal under Section 260A of the Income-tax Act, 1961, concurrent findings of fact on eligibility for deduction cannot be interfered with unless the case discloses a substantial question of law.

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