Turnover enhancement based on relevant material remains a question of fact, with no question of law arising absent supporting evidence.

The Tribunal's reduction of an estimated turnover enhancement was treated as a factual determination because it reappraised the stock discrepancy, rejected presumptive elements of the assessment, and fixed the figure by reference to the detected broken rice, market value, and returned turnover. The Court held that the quantum of enhancement, when supported by relevant material, ordinarily raises no question of law. A question of law would arise only if the conclusion were unsupported by any material. On that basis, no question of law arose and the reference was declined.

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Issues: Whether the Tribunal's reduction of the enhancement in turnover from Rs. 65,89,000 to Rs. 6,00,000 gave rise to a question of law warranting reference.

Analysis: The assessment arose from a discrepancy in stock of broken rice and the assessing authority enhanced the turnover on an estimated basis. The Tribunal re-examined the material, rejected parts of the estimation as presumptive, took the market value of the detected broken rice into account, and fixed a lower enhancement after considering the overall facts, including the returned turnover. The Court held that the quantum of enhancement, where based on an appraisal of relevant facts and materials, is ordinarily a conclusion on facts. A question of law would arise only where there is no material at all to support the conclusion.

Conclusion: No question of law arose from the Tribunal's order, and the Court declined to answer the referred question.

Final Conclusion: The reference was not entertained on merits because the Tribunal's fixation of enhancement was treated as a factual determination based on relevant materials.

Ratio Decidendi: The quantum of enhancement fixed by the Tribunal on consideration of relevant facts and materials is a finding on facts and does not, by itself, raise a question of law unless it is unsupported by any material.

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