Reference jurisdiction is limited to questions of law; vague and dependent referred questions could not be entertained.

Reference jurisdiction under the sales tax provisions is confined to questions of law and cannot be used as a first appellate review of evidence. A finding may raise a question of law only if it is unsupported by evidence, perverse, inconsistent with the evidence, based on irrelevant material, or reflects non-application of mind. The Tribunal's first referred question was vague and uncertain, and the statement of the case did not supply the material needed to test the alleged evidentiary defects. As the second and third questions depended on the first, the High Court held that the reference could not be entertained as framed.

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Issues: Whether the questions referred by the Sales Tax Tribunal were questions of law capable of being answered in reference jurisdiction.

Analysis: The reference jurisdiction under the relevant sales tax provisions is confined to deciding questions of law, and the High Court cannot be converted into a regular first appellate forum for reappreciation of evidence. A finding can give rise to a question of law where it is based on no evidence, is perverse, is inconsistent with the evidence, rests on irrelevant material, or reflects non-application of mind. On the facts placed before the Court, the Tribunal's first question was found to be vague and uncertain, and the material necessary to test the alleged use of irrelevant or exclusion of relevant evidence was not available in the statement of the case. Since the second and third questions depended on the first, the Court held that the reference could not be entertained as framed.

Conclusion: The referred questions were not questions of law and were incapable of being answered in the reference as framed.

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