2019 (1) TMI 601

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....y and tenacity with which Mr. Dudheria has argued this appeal on behalf of the revenue. The appeal that we entertain is under section 260A of the Income Tax Act, 1961. This section clearly provides that the appeal can only be maintainable before the High Court on a substantial question of law. Prior to the High Court the issue usually does three rounds. First before the Assessing Officer, second ....

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....g anything contained in any other provision of this Act, such unexplained expenditure which is deemed to be the income of the assessee shall not be allowed as a deduction under any head of income.]" The wording of this section suggests that it concerns only facts. No element of law is involved here save and except finding of facts which would amount to perversity in the finding of facts. In the ....