Reference jurisdiction requires a genuine question of law; purely factual disputes were not referable from the Tribunal's order.

The reference application failed because the proposed questions did not disclose any referable question of law arising from the Tribunal's appellate order. The first four questions were held to be factual, relating to tax-paid purchases without bills, exemption for groundnut husk under a government notification, and tax on cancelled bills. The remaining questions were also not referable because they either did not arise from the order or depended on disputed facts not shown to have been urged before the Tribunal. The High Court therefore held that no reference was required and dismissed the application.

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Issues: Whether the Tribunal was bound to refer the proposed questions to the High Court under the reference jurisdiction when the matters raised did not disclose any question of law arising from its order.

Analysis: The application under the reference provision sought answers on refusal to accept tax-paid purchases for want of bills, alleged exemption on groundnut husk under a government notification, and tax on cancelled bills. The Court found that the first four questions were essentially factual and did not raise any question of law. The remaining questions were also not referable because the alleged grounds either did not arise from the Tribunal's order or rested on disputed facts not shown to have been urged before the Tribunal. On that basis, the Court held that no referable question of law emerged from the appellate order.

Conclusion: The Tribunal was not required to make a reference, and the application was dismissed.

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