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2005 (3) TMI 69 - MADHYA PRADESH HIGH COURTWhether the appeal involves any substantial question of law within the meaning of section 260A – whether addition on account of cash which was seized during search can be sustained? - Whether on the basis of transaction of two days as reflected from the documents seized, income of entire block period can be estimated at Rs. 16,87,500 instead of Rs. 2,40,841 (Rs. 12,62,000 - Rs. 10,21,159) which remained unexplained in view of the documents and cash seized?" - It is essentially a question of fact because it is required to be decided on factual explanation and the nature of evidence (oral/documentary) tendered by the assessee in the assessment proceedings before the taxing authorities - - In our opinion, what is really involved in the appeal is a pure question of fact and not any question of law much less a substantial question of law contemplated under section 260A – Appeal of assessee is dismissed in limine.
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