HC can’t interfere with finding of facts recorded by ITAT without specific question of law: SC

Case Details: Muthoot Leasing and Finance Ltd. v. Commissioner of Income-tax - [2023] 146 taxmann.com 53 (SC)

Judiciary and Counsel Details

• • Sanjiv Khanna & M.M. Sundresh, JJ.

Facts of the Case

In the instant case, the Hon’ble Supreme Court held that the findings of fact generally recorded by the ITAT are treated as conclusive. The High Court can interfere with the findings of fact while deciding a substantial question of law when the findings are not supported by the material on record, so as to be treated as perverse. For this, however, the High Court must frame a separate substantial question of law and only then interfere with the findings of fact by the ITAT, while applying the strict parameters.

Supreme Court Held

In the present case, the High Court did not frame a specific substantial question of law and thus, the interference with the findings of fact is unwarranted. Accordingly, the additions made by the AO and affirmed by the High Court are deleted and the order passed by the ITAT is affirmed.