Concurrent factual findings on seized-document attribution remain binding unless perversity is established in a Section 260A appeal.

Concurrent factual findings on the attribution of a seized document cannot be disturbed in an appeal under Section 260A unless shown to be perverse. Where the original seized document was unavailable and the appellate authorities found that the scanned entry referred to another entity rather than the assessee, the challenge raised only a factual dispute. The High Court found no perversity in that concurrent finding and therefore declined interference, deciding the issue in favour of the assessee.

---

---

Issues: Whether the concurrent appellate finding that the seized document did not implicate the assessee was perverse and warranted interference in an appeal under Section 260A.

Analysis: The Revenue could not produce the original seized document despite opportunities. The challenge consequently rested on a factual contention concerning the reading and attribution of the entry in the scanned document. The appellate authorities had concurrently found that the entry referred to another entity and could not be attributed to the assessee; that finding was not shown to be perverse.

Conclusion: No interference with the concurrent factual finding was warranted; the issue was decided in favour of the assessee.

Ratio Decidendi: A concurrent factual finding cannot be interfered with in an appeal under Section 260A unless it is demonstrated to be perverse.

---