“6. On a perusal of the Tribunal’s order, we find that each of the contentions raised by the assessee has been negatived on a reference to the materials on record. Plea that the seized documents did not belong to the assessee is clearly untenable and the Tribunal was justified in its conclusion that the seized documents belonged to the assessee. The fact that the signatures of various supervisors and details regarding working of shifts, power break down, bags manufactured in each shift evidently show that books belonged to the petitioner company and to none else. Similarly, other aspects high lighted by petitioner as referred to above, all relate to factual disputes on which Tribunal has recorded its findings after referring to materials on record. Such factual findings and conclusions do not give rise to any question of law, where the determination of an issue depends upon the appreciation of evidence or materials resulting in ascertainment of basic facts without application of any principle of law, the issue raises a mere question of fact. In such cases the Tribunal is the final fact finding authority and if upon examination of all evidence and material it reaches certain findings, decision relates to existence or otherwise of certain facts at issue (See Sree meenakshi Mills Ltd. v. Commissioner of Income Tax – (1957) 31 ITR 28).
