No substantial question of law arises where concurrent search-assessment findings on additions are supported by seized material and statements.

Concurrent factual findings by the CIT(A) and ITAT on additions arising from search assessments did not give rise to any substantial question of law under section 260A. The Court noted that the disputed advances, interest and cash transactions were examined from seized papers, recorded statements and the post-search cash book, and found no perversity or legal error in the Tribunal's approach. Interference was therefore declined.

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Issues: Whether the Tribunal's concurrent findings upholding the additions for the assessment year in question gave rise to any substantial question of law warranting interference in an appeal under section 260A of the Income-tax Act, 1961.

Analysis: The appeal arose from a common search assessment order where the authorities had examined seized papers, statements recorded during search and post-search proceedings, and the cash book prepared after the search. The Court noted that the Commissioner (Appeals) and the Tribunal had returned concurrent factual findings on the disputed additions, including the alleged advances, interest, and other cash transactions, on the basis of the seized material and the assessee's statements. It was held that the grievance related only to one assessment year, but the impugned orders were passed as composite orders after considering the overall factual matrix for the search block assessments. On those facts, the Court found no perversity or legal error in the Tribunal's approach.

Conclusion: No substantial question of law arose and interference was not called for.

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