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Issues:
1. Appeal against order under section 260A of the Income-tax Act, 1961 for assessment year 1991-92. 2. Disallowance of cash credit of Rs. 1,40,000 in the name of Mrs. Mehrunnisa Begum. 3. Determination of substantial question of law under section 260A of the Act. Analysis: 1. The appellant, a partnership firm, appealed against an order passed by the Income-tax Appellate Tribunal for the assessment year 1991-92, challenging additions made under section 69 of the Income-tax Act, totaling Rs. 10,05,000 as loans received from different parties. The appellant contended that the Assessing Officer's presumptions were unfounded as parties confirmed the loans were from their own sources via account payee cheques. The Appellate Tribunal upheld the Commissioner's decision on one transaction but allowed the appeal for the other four transactions, leading to the current appeal under section 260A of the Act. 2. The main issue revolved around the disallowed cash credit of Rs. 1,40,000 in the name of Mrs. Mehrunnisa Begum. The appellant argued that the Assessing Officer and the Appellate Tribunal erred in finding no acceptable evidence to prove the cash credit. Despite confirmatory letters submitted by the appellant, they were not admitted due to procedural rules. The Assessing Officer's report highlighted Mrs. Mehrunnisa's lack of knowledge about the transactions and her husband's involvement, leading to the disallowance. The Commissioner and the Appellate Tribunal concurred with this finding, emphasizing the appellant's failure to substantiate the cash credit. 3. The determination of whether a substantial question of law existed under section 260A of the Act was crucial. The High Court clarified that for a question to be substantial, it must be of general public importance or directly affect parties' rights, not settled by higher courts, and involve difficulty or alternative views. In this case, the disallowance of the cash credit did not raise any substantial question of law. The court emphasized the appellant's burden under section 69 to prove the nature and source of investments, failing which unexplained investments are assessable. Citing precedents, the court dismissed the appeal, stating it did not involve any question of law, let alone a substantial one. This detailed analysis of the judgment from the Andhra Pradesh High Court showcases the legal intricacies involved in the appeal under the Income-tax Act, emphasizing the burden of proof on the appellant and the court's criteria for determining substantial questions of law under section 260A.
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