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The High Court held that the appeal did not involve any substantial question of law. The Court reasoned that the case primarily involved a pure question of fact, and the High Court, in its appellate jurisdiction under Section 260A, cannot re-examine factual issues or draw factual inferences. The Court noted that both the CIT(A) and the ITAT had examined the assessee's explanation and the supporting evidence in detail before accepting it. Since these two appellate authorities arrived at concurrent findings of fact, such findings are binding on the High Court. The Court stated that it would not conduct a de novo factual inquiry to determine the validity of the assessee's explanation. Therefore, the appeal was dismissed, with the Court holding that it did not involve any substantial question of law, or if it did, it was answered against the appellant (Revenue) and in favor of the respondent (assessee).
