Substantial Question of Law absent where addition based on a search statement turned on factual findings, leaving Tribunal's view undisturbed.

Addition based on a statement recorded under section 132(4) was treated as a factual issue, and the HC held that no substantial question of law arose for interference under section 260A. The Tribunal had given factual reasons for restoring the addition made on the basis of the partner's search statement, and the Court found those findings did not require appellate adjudication as a legal question. The Court therefore declined to answer the proposed question as a substantial question of law and left the Tribunal's factual determination undisturbed.

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Issues: Whether the appeal raised any substantial question of law warranting interference on the addition made on the basis of a statement recorded under section 132(4) of the Income-tax Act, 1961.

Analysis: The Tribunal had dealt with the addition of Rs. 1,50,000 on the basis of the partner's statement recorded during search proceedings and had recorded factual reasons for restoring the addition. The Court found that the proposed question was essentially factual in nature and that the Tribunal's discussion did not give rise to a substantial question of law requiring adjudication under section 260A of the Income-tax Act, 1961.

Conclusion: The Court declined to answer the question as a substantial question of law and did not interfere with the Tribunal's factual findings.

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