Concurrent factual findings bar interference in tax appeal where Form 26AS mismatch challenge raised no substantial question of law.

In an appeal under Section 260A of the Income-tax Act, the High Court held that interference was not justified because the dispute turned on concurrent factual findings about contract receipts, running bills, and bank entries. The revenue's challenge to the deletion of an addition based on the alleged mismatch between Form 26AS and the books of account was treated as a question of evidence and verification, not a substantial question of law. As no legal error of principle was shown, the deletion of the addition was upheld and the revenue's appeal failed.

---

---

Issues: Whether the deletion of the addition made on the basis of the alleged difference between Form 26AS and the books of account was justified, and whether any substantial question of law arose for consideration in the revenue's appeal.

Analysis: The appeal under Section 260A of the Income-tax Act, 1961 could succeed only if a substantial question of law arose. The record showed that the lower appellate authority and the Tribunal had examined the contract receipts, the running bills, and the bank account entries, and had reached concurrent factual findings that the addition was not warranted. The challenge raised by the revenue was essentially to the appreciation of evidence and verification of receipts, not to any legal error of principle.

Conclusion: The deletion of the addition was upheld and no substantial question of law was found to arise. The issue was decided in favour of the assessee and against the revenue.

Final Conclusion: The revenue's appeal was dismissed as it failed to disclose any substantial question of law warranting interference with the concurrent factual findings.

Ratio Decidendi: In an appeal under Section 260A of the Income-tax Act, 1961, interference is not justified where the challenge is confined to concurrent findings of fact on verification of receipts and accounts and no substantial question of law arises.

---