Substantial question of law controls appeals; concurrent factual findings supported by evidence cannot be reappreciated on appeal.

An appeal under the Income tax Act is maintainable only on substantial questions of law; concurrent findings of fact supported by evidence and free from perversity cannot be reappreciated on such appeal. The Tribunal properly confirmed additions after noting notices to customers, ledger entries dominated by cash, unconvincing DD explanations, customers' denials and non traceability, and the appellant's failure to produce creditworthy documents or witnesses. Reliance on customers' replies did not breach procedure where no request for cross examination appears and the appellant had opportunity to summon witnesses; therefore no substantial question of law arises to entertain the appellate forum.

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Issues: (i) Whether the Tribunal was justified in confirming additions without considering the appellant's oral and written submissions and material documents; (ii) Whether the Tribunal was justified in confirming additions in absence of corroborative evidence and by ignoring the appellant's submissions; (iii) Whether the Tribunal was justified in relying solely on replies of two customers without allowing the appellant an opportunity to cross-examine them.

Issue (i): Whether the Tribunal was justified in confirming the addition without considering the appellant's oral and written submissions and material documents.

Analysis: Notices were issued to the customers and their responses or non-traceability were on record. The ledger entries were predominantly cash and explanations regarding demand drafts were unconvincing. The Revenue discharged initial burden and concurrent authorities recorded findings of fact. The appellate scope under Section 260-A is limited to substantial questions of law, not reappreciation of evidence.

Conclusion: The Tribunal was justified; the matter involves appreciation of evidence and does not raise a substantial question of law against the appellant.

Issue (ii): Whether the Tribunal was justified in confirming the addition in absence of corroborative evidence and by ignoring the appellant's submissions.

Analysis: The record contains customers' denials and instances of non-service/non-traceability. The appellant failed to produce creditworthy documents or to call customers as witnesses to discharge the onus shifted to it. Concurrent findings by three authorities addressed the submissions and found the appellant's explanations inadequate.

Conclusion: The Tribunal was justified; absence of corroboration and failure by the appellant to discharge onus sustain the additions and do not constitute substantial questions of law in favour of the appellant.

Issue (iii): Whether the Tribunal was justified in relying solely on replies of two customers without allowing the appellant an opportunity to cross-examine them.

Analysis: There is no record of a request for cross-examination having been made and refused. The appellant could have produced the customers if transactions were genuine. Reliance on customer responses and circumstances of non-traceability formed part of factual findings examined by concurrent authorities.

Conclusion: The Tribunal was justified; no substantial question of law arises from the reliance on customer replies and no procedural lapse mandating interference is established.

Final Conclusion: The questions framed do not amount to substantial questions of law under Section 260-A and do not justify entertaining the appeal; concurrent findings of fact are not susceptible to reappreciation in this appellate forum.

Ratio Decidendi: An appeal under Section 260-A of the Income-tax Act, 1961 is maintainable only on substantial questions of law; concurrent findings of fact supported by evidence and free from perversity do not give rise to such questions and cannot be reappreciated in that appeal.

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