Concurrent findings of fact in search assessment additions can bar a substantial question of law under Section 260A.

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....In a search assessment, additions for unaccounted advances and cash receipts were upheld on the basis of composite appellate orders and concurrent findings of fact drawn from seized material. The High Court held that the Commissioner (Appeals) and the Tribunal had considered the entire record across the relevant years, and the Tribunal's lack of separate elaborate reasoning for one year did not, by itself, justify remand. Because the dispute turned on appreciation of evidence and factual conclusions, no substantial question of law arose under Section 260A, and the appeal was dismissed.....