Findings of fact cannot be disturbed unless unsupported by evidence or perverse; Bombay contract profits remained taxable.

A finding of fact by income-tax authorities is not open to interference merely because another view is possible; interference lies only where the finding is unsupported by evidence or is perverse. Applying that standard, the Court accepted the Tribunal's conclusion that the forward contracts were made at Bombay and that the profits accrued there. Direct testimony and surrounding circumstances supported that finding, and the objections to parts of the evidence did not show any material misdirection or evidentiary gap. The Tribunal's finding was therefore upheld, and the profits remained taxable under the Act.

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Issues: Whether the Tribunal's finding that the forward contracts were concluded at Bombay and that the resulting profits were taxable could be interfered with on the ground that it was unsupported by evidence or was perverse.

Analysis: The decision turned on a question of fact, namely where the contracts were made and where the profits accrued. A finding of fact is open to interference only if there is no evidence to support it or if it is perverse. The record contained direct testimony and supporting circumstances indicating that the contracts were made in Bombay and that the interposition of the Gwalior brokers was merely a device. The objections directed against parts of the evidence did not establish that the finding lacked evidentiary support, nor did they show any material misdirection or non-direction affecting the result.

Conclusion: The Tribunal's finding was upheld, and the profits were held taxable under the Act.

Ratio Decidendi: A finding of fact by the income-tax authorities is not open to challenge in reference or appeal merely because another view is possible; interference is warranted only where the finding is unsupported by evidence or is perverse.

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