Perversity in factual findings was not established where sales were accepted as genuine on possible evidence-based views.

Additions based on allegedly artificial sales and rejection of books require material showing that invoices were fabricated or book entries were false. A comparison with earlier transactions is insufficient where the disputed sales arose in materially different circumstances, including increased customer demand during demonetization. The Tribunal treated the sales as genuine on its factual appraisal, as both genuine and accommodation-sale explanations were possible on the evidence. The Rajasthan HC found that this factual conclusion was not perverse and that no substantial question of law arose.

---

---

Issues: Whether the Tribunal's deletion of additions based on allegedly artificial sales and rejection of books of account was perverse, giving rise to a substantial question of law.

Analysis: The additions rested on a comparison between disputed sales and the assessee's earlier transactions, without material establishing that the underlying invoices were fabricated or that the book entries were false. The disputed sales occurred in circumstances materially different from the comparative transactions, including increased customer demand during demonetization. On the evidence, both genuine sales and artificial accommodation sales were possible views; the Tribunal, as final fact-finding authority, adopted the former view on appreciation of facts.

Conclusion: The Tribunal's findings were not perverse and no substantial question of law arose; the issue was decided in favour of the assessee.

---