Dismissing the appeal of the assessee the Court held that the question was whether the explanation given by the assessee for the cash deposits in his personal bank account was substantiated by materials or evidence on record. The Appellate Commissioner, in substance, held that there were no materials to explain the deposits. No substantial question of law was involved in this appeal. The Tribunal was justified in refusing to condone the delay in the filing of appeal. Court also observed that even in a case where an appeal was not entertained on the ground of limitation, if there was a serious issue of law involved in the appeal, the court might consider that issue as an issue of law for entertaining an appeal under S. 260A of the Act .(AY.2009-10)