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Issues: Whether any referable question of law arose from the Tribunal's order so as to warrant reference under section 256(2) of the Income-tax Act, 1961.
Analysis: The dispute in both references turned on additions made in reassessment proceedings, one concerning unexplained investment in money-lending business and the other concerning interest income from undisclosed sources. In the first matter, the Tribunal restricted the addition by adopting the peak credit method and sustained only the reduced amount. In the second, the Tribunal deleted the consequential addition after the main addition had already been deleted in appellate proceedings. On these facts, the controversy was concluded by findings of fact and consequential adjustment, leaving no substantial or referable question of law for reference.
Conclusion: No referable question of law arose, and the reference applications were rightly rejected.