The HC dismissed the petition and upheld the assessment, finding...

The HC dismissed the petition and upheld the assessment, finding concurrent findings of fact by the AO and the Tribunal that the appellant suppressed income and that requirements of s.158BD (and related provisions) were satisfied. The Tribunal's reliance on witness testimony and documentary material supported the AO's satisfaction that undisclosed income pertained to the appellant. The Court held the matter did not raise a substantial question of law under s.260A but merely questions of fact and application of settled statutory provisions; accordingly the assessment under the relevant provisions was sustained and the challenge on the ground of absence of recorded satisfaction by the AO failed.