Concurrent factual findings barred interference with deletion of addition for bank-credit mismatch under appellate principles.

Concurrent factual findings supported deletion of an addition based on the difference between bank credits and receipts recorded in the books of account, because the assessee furnished documentary explanation and the Assessing Officer had proceeded on suspicion without proper verification. The CIT(A) held the addition unsustainable, and the ITAT agreed that the Revenue had not controverted those findings and no further evidence issue survived. The High Court declined interference, holding that appellate review is confined to substantial questions of law and does not permit mere reappreciation of evidence where the lower authorities have reached concurrent findings on the record.

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Issues: Whether the Revenue could succeed in challenging the deletion of the addition made on account of the difference between the Assessee's bank credits and the receipts reflected in the books of account, in the absence of any substantial question of law arising from the concurrent factual findings recorded by the lower authorities.

Analysis: The CIT(A) accepted the Assessee's documentary explanation for the difference and held that the addition was unsustainable, noting that the Assessing Officer had not made a sincere verification and had proceeded on suspicion without adequate opportunity of hearing. The ITAT concurred, recording that the Revenue failed to controvert the findings of the CIT(A) and that no additional evidence issue survived. In appeal, the High Court found that both fact-finding authorities had returned concurrent findings based on the material on record, and no material was produced to dislodge those findings. In such a situation, interference was not warranted, as appellate interference is confined to substantial questions of law and does not extend to mere reappreciation of evidence.

Conclusion: The challenge to the deletion of the addition was rejected, and the appeal was held to be without merit.

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