Dismissing the appeal, that the conclusion arrived at by the Tribunal regarding the claim of the assessee under section 10A of the Act was based upon concurrent findings of fact recorded by it after appreciating the material on record. Since the appeal was based purely upon the findings of fact recorded after appreciation of the evidence on record, in the absence of any perversity, it would not give rise to any question of law. ( AY. 2007 -08)