No substantial question of law in Section 260A appeal where deletion of Section 68 additions rested on factual appreciation.

No substantial question of law arose in the revenue's Section 260A appeal because the first appellate authority and the Tribunal had deleted the Section 68 additions on a detailed factual appreciation of the record and the assessee's explanation. The High Court found no legal error in that evaluation and held that interference is not warranted where the dispute is confined to facts. The revenue's challenge therefore failed.

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Issues: Whether any substantial question of law arose in the revenue's appeal against deletion of additions made under Section 68 of the Income-tax Act, 1961.

Analysis: The factual findings recorded by the first appellate authority and affirmed by the Tribunal were based on a detailed examination of the materials on record and the assessee's explanation. The challenge raised did not disclose any legal error in the appreciation of facts. In an appeal under Section 260A of the Income-tax Act, 1961, interference is not warranted where the controversy is confined to factual appreciation and no substantial question of law is shown to arise.

Conclusion: No substantial question of law arose for consideration, and the revenue's challenge to the deletion of the additions failed.

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