Concurrent findings of fact defeated the challenge to proportionate allocation of employees' benefit expenses under income-tax law.

The Gujarat HC treated the Tribunal's view on proportionate allocation of employees' benefit expenses as a concurrent finding of fact. The assessee had not produced supporting evidence for claiming that salary and wages were attributable to agricultural activity, and the Tribunal, as final fact-finding authority, upheld the revenue's allocation after considering the nature of the operations and the record. The Court declined to reappreciate the evidence in an appeal under section 260A of the Income-tax Act, 1961, and held that no substantial question of law arose. The challenge to the allocation therefore failed.

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Issues: Whether the Tribunal was justified in upholding the allocation of employees benefit expenses on proportionate revenue basis and, on that basis, whether any substantial question of law arose for interference under section 260A of the Income-tax Act, 1961.

Analysis: The Tribunal's finding that the assessee had not produced supporting evidence for the claimed allocation of salary and wages to agricultural activity was treated as a concurrent finding of fact. The Court declined to reappreciate the evidence, noting that the Tribunal, as the final fact-finding authority, had upheld the revenue's proportionate allocation after considering the nature of the agricultural operations and the material on record.

Conclusion: The issue was answered against the assessee. No substantial question of law arose from the Tribunal's order, and the challenge to the allocation of employees benefit expenses failed.

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