Concurrent findings on bogus purchases barred Section 260A interference absent perversity; appeals failed.

In an appeal under Section 260A of the Income-tax Act, the High Court held that interference was unavailable where the assessing authority, CIT(A) and the Tribunal had concurrently found purchases to be bogus and had sustained an estimated addition. The challenge amounted to re-appreciation of evidence, which lies outside the scope of a substantial question of law unless perversity is shown. As the findings were supported by material, did not ignore relevant evidence, and were not based on no evidence, no perversity was established. Authorities cited on supplier non-appearance were fact-specific and did not assist the taxpayers. No substantial question of law arose, and the appeals failed.

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Issues: Whether any substantial question of law arose from concurrent findings that the purchases were bogus and that the addition was to be sustained at a reduced estimated percentage; whether such concurrent factual findings were vitiated by perversity.

Analysis: The appeals arose under Section 260A of the Income-tax Act, 1961, where interference is confined to substantial questions of law. The assessing authority, the Commissioner of Income Tax (Appeals), and the Tribunal had concurrently found, on the basis of the material on record, that the purchases were bogus and that the books of account were liable to be rejected. The challenge required re-appreciation of evidence, which is outside the normal scope of a Section 260A appeal unless perversity is shown. No case of perversity was made out, since the findings were supported by material and were neither based on no evidence nor rendered by ignoring relevant evidence. The cited decisions on supplier non-appearance turned on their own facts and did not assist the appellants.

Conclusion: No substantial question of law arose. The concurrent findings sustaining the bogus purchase addition were not shown to be perverse, and the appeals failed.

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