Exemption for transfer of property to minor sons for education treated as a factual determination, leaving no question of law.

Transfer of a comparatively small portion of immovable property to minor sons for education was treated as an issue turning on the facts of each case, including whether the transfer remained within a reasonable limit. The appellate authorities examined the material in detail and characterised the availability of exemption under the relevant provision as a factual determination rather than a legal question. On that basis, no question of law was held to arise from the Tribunal's order, and the reference application was rejected.

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Issues: Whether the Tribunal's finding that the transfer of immovable property to minor sons for education was entitled to exemption was a finding of fact giving rise to no question of law.

Analysis: The appellate authorities had examined the material in detail and found that only a comparatively small portion of the assessee's property was transferred for meeting the educational needs of the minor sons. The question whether the transfer was within a reasonable limit was treated as depending on the facts of each case. On that basis, the finding that exemption was available under the relevant provision was characterised as a factual determination.

Conclusion: No question of law arose from the Tribunal's order and the reference application was rejected.

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