Referable question of law absent after reassessment was set aside and fresh assessment directed.

Reassessment under section 147(a) read with section 148 was set aside by the appellate authority with a direction to make a fresh assessment, and the Tribunal affirmed that order. In view of the subsequent fresh assessment made in compliance with those directions, there was no surviving basis to interfere or to frame a referable question of law. The reference application was therefore disposed of against the Revenue.

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Issues: Whether any referable question of law arose from the Tribunal's order affirming the appellate order setting aside the assessment and directing a fresh assessment.

Analysis: The reassessment for the relevant assessment year had been made under section 147(a) read with section 148 of the Income-tax Act, and the appellate authority had set aside that assessment with a direction to reframe it. The Tribunal affirmed that view. In the light of the subsequent fresh assessment made in compliance with those directions, and the Tribunal's confirmation of the appellate order, there was no surviving basis to interfere or to frame a referable question of law.

Conclusion: No referable question of law arose; the reference application was disposed of against the Revenue.

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