Section 260A of the Income-tax Act, 1961—Appeal — Appeal to High Court- The acceptance of one view on facts as against another, unless it showed to be wholly unreasonable, cannot be subject matter of an appeal under section 260A.

Facts: Ground pressed in this appeal is that ITAT fell into error in not noticing the true nature of the transaction for refund of the advance amounts received by the assessee from the vendee company of which, he was a director.

Held, that Court is of the opinion that the ITAT's decision is based upon an independent analysis of the facts. No doubt it differed from the CIT(A)'s view. At the same time all its findings are based upon appreciation of material facts. Its conclusion are a possible view that can be taken by the Tribunal based upon the circumstances. The acceptance of one view on facts as against another, unless it showed to be wholly unreasonable, cannot be subject matter of an appeal under section 260A. - VIKRAM KRISHNA V/s PR. CIT - [2019] 11 ITCD Online 51 (DEL)