Factual Examination Of Dispute Regarding 'Addition' Of Unexplained Cash Credit U/S 68 Of IT Act Is Beyond Scope Of Appeal U/S 260A: Calcutta HC

The Calcutta High Court ruled that factual examination of disputes under Section 68 of the Income Tax Act is beyond the scope of appeal under Section 260A. The case involved an addition made by the Assessing Officer (AO) for unexplained cash credits, which was upheld by the Commissioner of Income Tax (Appeals) [CIT(A)] and the Income Tax Appellate Tribunal (ITAT). The High Court emphasized that appeals under Section 260A are limited to substantial questions of law and do not extend to re-evaluating factual determinations made by lower authorities. This ruling clarifies the scope of appellate review in tax cases, ensuring that factual disputes are resolved at the appropriate levels.