The Tribunal elaborated upon the contents of the so called incriminating material, Le. GCL-HD-1 and recorded its conclusions while concurring with the findings of the CIT(A), which had concluded that this document was not an incriminating material and simply contained a shareholding pattern of the assessee which was duly verifiable from the books of accounts and other secretarial records tiled by the assessee with ROC prior to the date of search. The issue whether a document, which in these cases is the electronic device in the form of a hard drive extracted from the computer of the assessee during search constitutes incriminating material or not, would unquestionably require evaluation, assessment and appreciation of contents of such document which is an exercise of evaluation of evidentiary worth of the document. Thus, this Court has no doubt in its mind that the conclusions recorded on the nature of contents of the document by the competent forum, be it the CIT(A) or the Tribunal as to whether the same was incriminating or not, would definitely be findings of fact and hence, the proposed substantial question of law in all these appeals, which is the primary ground for assailing the judgment passed by the Tribunal and seeking admission of the appeals, cannot be considered to be a substantial question of law. (AY.  2011-12 to 2015-16,  2017-18)