Dismissing the appeal of the assessee the Court held that the Commissioner (Appeals) was justified in taking the cost of acquisition of the books inherited and sold at the rate of 30 per cent. of the sale value because the assessee had failed to prove the cost of acquisition. In the absence of cost of acquisition as on April 1, 1981 having been established by the assessees, the benefit of indexation of cost could not be given. The findings of fact on the basis of estimate none the less remained findings of fact and did not give rise to any question of law which warranted interference under section 260A. (AY.1995-96 to 1999-2000)