Complete statement of case required for sales tax references; incomplete factual records justify return for fresh preparation.

A sales tax reference must be supported by a complete statement of the relevant facts found or admitted, with necessary documents, because a mere recital of procedural history and framed questions is insufficient. Where the revising authority omits those facts, the court may return the reference for preparation of a fresh and complete statement of case before resubmission.

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Issues: Whether the reference could be answered when the statement of case submitted by the revising authority did not set out the relevant facts, and whether the references should be returned for a fresh and complete statement of case.

Analysis: A reference under the sales tax reference provision requires the revising authority to place before the court all facts relevant to the question of law, namely the facts found by it or admitted between the parties, together with necessary documents. A mere recital of the procedural history and the questions framed is insufficient. The proper course is to prepare a draft statement, invite suggestions from the parties, and then finalise a complete statement of case before submission to the court.

Conclusion: The references could not be decided on the incomplete material placed before the court, and they were returned for submission of fresh references with a full and complete statement of the case in each matter.

Final Conclusion: The matter was disposed of on a procedural deficiency in the reference record, with no determination on the substantive tax questions referred.

Ratio Decidendi: A reference on a question of law must be supported by a complete statement of the relevant facts found or admitted, and without such a statement the court may return the reference for proper preparation.

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