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2010 (7) TMI 37 - HC - Income TaxSearch and seizure evidence collected during search ITAT held that no documentary proof was found at the time of search to show pledging of jewellery by 41 persons ITAT also observed that statement given by 4 persons in favour of the appellant is not supported by any evidence. Held that: - Tribunal has given cogent reasons for its conclusion and that the appellant has, in the present proceedings essentially challenged findings of fact - a question of fact becomes a question of law, if the finding is either without any evidence or material, or if the finding is contrary to the evidence, or is perverse or there is no direct nexus between conclusion of fact and the primary fact upon which that conclusion is based - But, it is not possible to turn a mere question of fact into question of law by seeking whether as a matter of law the authority came to a correct conclusion upon a matter of fact. appeal dismissed
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