The assessee, engaged in the business of construction of roads and other infrastructure works, claimed deduction under section 80-IA(4) for the relevant assessment year. The Assessing Officer disallowed the claim, treating the assessee as a works contractor. The CIT(A) allowed the deduction and the Tribunal affirmed the finding, relying upon its earlier order, which had been confirmed by the High Court. The High Court held that the Department had failed to demonstrate that the concurrent findings were perverse or that an erroneous legal test had been applied. Section 260A does not confer general appellate jurisdiction to reappreciate evidence or substitute the Court’s view for concurrent findings on questions of fact. As no substantial question of law arose, the appeal was dismissed. The Court also observed that departmental appeals under section 260A should not be filed routinely by mechanically framing purported substantial questions of law.  The Court observed that the Departmental Authorities should look into these aspects of the matter and take corrective step(s), as may be deemed necessary. Copy was forwarded to the PCIT .   (AY. 2011 -12 ) ( ITA No. 2691 of 2018 , dt. 23-09-2026)