JUDGMENT N.K. Patil, J.— This appeal by the Assessee is arising out of the impugned order dated 22-7-2005 vide Annexure A, passed in WTA Nos. 43 & 44/ Bang./2004 by the Income-tax Appellate Tribunal, Bangalore, for consideration of the following substantial questions of law: i. Whether on the facts and in the circumstances of the case, the Tribunal was right in holding that the Appeallent was entitled to the deduction of proportionate debt as declared in the balance sheet in relation to the assets declared under Section 2(m) of the Wealth-tax Act? ii. When theAppellant was carrying on the business and had also drawn up balance sheet, wherein all the assets and liabilities were declared, whether Rule 14 of part D of III Schedule was required to be applied to determine the Net Wealth and by that process theAppellant was entitled to the deduction of debts in proportion to the value of the assets declared. 2. The facts in brief are, theAssessee has filed Return of Wealth under the Wealth-tax Act, before the Assessing Officer, for the assessment years 1997-98 and 1998-99 claiming deduction for proportionate liabilities. The Assessing Officer has declined to allow the claim for deduction under Section 2(m) of the Act in respect of the same, on the ground that, in spite of giving sufficient opportunity to theAssessee, he has failed to prove that the proportionate loans claimed had actually been invested in the proper ties offered for Wealth Tax, by its order dated 26-3-2002. Assailing the correctness of the said order, theAssessee has filed the appeals before the First Appellate Authority--the Commissioner of Income-tax (Appeals), Hubli, in appeal Nos. 304 & 305 HBL/CIT(A)HBL/2003-04. The said matter had come up for consideration before the First Appellate Authority on 9-7-2004. The First Appellate Authority, after hearing both sides and after going through the order passed by the Assessing Officer, has dismissed the said appeals, holding that only those liabilities are deductible which are incurred in relation to taxable assets and there is no correlation between the monies borrowed from M/s. Manipal Sowbhagya Nidhi Limited and the taxable assets and therefore, it is not an allowable deduction. Being aggrieved by the order of the First Appellate Authority and the Assessing Officer, theAssessee has filed appeals before the Income-tax Appellate Tribunal, Bangalore Bench, (Tribunal for short) in Appeal Nos. 43 & 44/ Bang./2004. Being aggrieved by the order of the First Appellate Authority and the Assessing Officer, theAssessee has filed appeals before the Income-tax Appellate Tribunal, Bangalore Bench, (Tribunal for short) in Appeal Nos. 43 & 44/ Bang./2004. The said matter came up for consideration before the Tribunal on 22-7-2005. The Tribunal, after hearing both sides, after appreciating the oral and documentary evidence available on file and after going through the orders passed by the Assessing Officer and the Commissioner of Income-tax (Appeals), Hubli, has dismissed the said appeals holding that, the debts are not incurred in relation to the assets forming part of Net Wealth, the liability is not allowable and there is no infirmity in the impugned order herein. Against the order passed by the Tribunal, theAssessee herein has presented this appeal, seeking appropriate reliefs as stated supra. 3. We have heard the learned Counsel for theAppellant and learned Counsel for theRespondent at considerable length of time. 4. The principal submission canvassed by the learned Counsel for theAppellant is that, even though theAppellant has produced all the necessary documents before the Tribunal to substantiate his case as to how he is entitled for deduction, the same has not been looked into or considered by the Tribunal. Therefore, he submitted that the order impugned is liable to be set aside and matter requires to be remanded back to the Assessing Officer to reconsider and decide the same after affording reasonable opportunity of hearing to theAppellant. 5. As Against this, learned Counsel forRespondent, inter alia, contended and substantiated the order passed by the Tribunal and submitted that, all the three authorities after considering the relevant material available on file, have recorded concurrent finding of fact and therefore, interference by this Court does not call for. Further, he submitted thatAppellant has not made out any good grounds to consider the substantial questions of law raised in this appeal. 6. After considering the submissions made by learned Counsel for both the parties, the only point that arises for our consideration is- Whether theAppellant has made out any case to interfere with the order passed by the Tribunal? 7. 6. After considering the submissions made by learned Counsel for both the parties, the only point that arises for our consideration is- Whether theAppellant has made out any case to interfere with the order passed by the Tribunal? 7. After perusal of the order passed by the Assessing Officer, it emerges that, in spite of giving sufficient opportunity to theAssessees representative to establish and to produce evidence towards the nexus between the loan availed has been utilized for purchase or development of properties which are the subject-matter, he has failed to produce any evidence to that effect and therefore, he has proceeded to pass the order of assessment. Against that order,Assessee had filed appeals before the First Appellate Authority. The First Appellate Authority, after considering the oral and documentary evidence available on file, has dismissed the said appeals and confirmed the order passed by the Assessing Officer holding that, as no evidence was produced by theAssessee, the Assessing Officer did not allow the liability claimed for the two assessment years. Further, the First Appellate Authority has observed that, one Mr. Sheik Abdul, Chartered Accountant, who was attended on behalf ofAssessee has been afforded reasonable opportunity for producing evidence to show as to whether the said loan taken from M/s. Manipal Sowbhagya Nidhi Limited was for the purpose of the properties that were subject to wealth-tax, but he has failed to do so and merely stated that the global method of valuation should be followed and the liability should be considered as a deduction. Further, it is observed that, when theAppellant was not prepared to give evidence regarding the said liability, these properties do not have any liability attached to them and the movable assessed also do not appear to have any liability by way of loan attached to them and therefore, there is no co- relation between monies borrowed from M/s. Manipal Sowbhagya Nidhi Limited and taxable assets and therefore, deduction is not allowable. Aggrieved by the said order, theAssessee has filed appeals before the Tribunal. The Tribunal after re-appreciating oral and documentary evidence and after going through the orders passed by the Assessing Officer and the First Appellate Authority, has dismissed the appeals holding that the debts are not incurred in relation to the assets forming part of net wealth and therefore, liability is not allowable and there is no infirmity in the order impugned therein. It is significant to note that, the Assessing Officer after evaluation of the oral and documentary evidence has passed the order recording a finding of fact and the same has been confirmed by both the First Appellate Authority and the Tribunal after re-appreciating the materials available on file. Therefore, in view of the concurrent finding of fact recorded by all the authorities, interference by this Court does not call for. Nor we find any infirmity or irregularity in the said orders. Keeping all these factors into consideration, the instant appeal is liable to be dismissed as devoid of merits and accordingly, it is dismissed. 8. In view of the dismissal of the appeal, the substantial questions of law framed in this appeal are answered in favour of the revenue.