Findings of fact, not a question of law, barred reference on house tax, interest and jewellery issues.

No referable question of law arose under section 256(2) because the Tribunal's conclusions turned on pure findings of fact. The allowance of house tax was found to have been made after due application of mind, and interest on the compulsory deposit account had already been taxed on receipt basis. On the jewellery issue, there was no material to show that the investment was made in the relevant previous year, so no basis existed to treat the assessment as prejudicial to the Revenue. The request for reference was rejected.

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Issues: Whether the proposed questions arising from the Tribunal's order involved any referable question of law under section 256(2) of the Income-tax Act, 1961.

Analysis: The Tribunal's conclusions rested on factual findings that the allowance of house tax had been made after due application of mind and that interest on the compulsory deposit account had earlier been brought to tax on receipt basis. On the jewellery issue, the Tribunal found no material to show that the investment was made in the relevant previous year, and thus no clear basis to hold the assessment prejudicial to the interests of the Revenue. Those findings were pure findings of fact and were not specifically assailed by the Revenue by any distinct question of law.

Conclusion: No question of law fit for reference arose, and the request for reference was rejected.

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