Question of fact, not law: Tribunal's finding on gunny bags and turnover deduction raised no referable legal issue.

The Tribunal's finding that there was no implied purchase of empty gunny bags with groundnuts, and that their sale value was not deductible from turnover, was treated as a factual determination rather than a question of law. The challenge that the finding was perverse failed because the material relied on had not been properly produced before the lower authorities, and the certificate was only weak evidence. The Tribunal's inference from the price material did not raise any legal issue for reference, so no answer was given.

---

---

Issues: Whether the Tribunal's finding that there was no implied purchase of empty gunny bags in the purchase of groundnuts, and that the sale value of such bags was not deductible from turnover, gave rise to a question of law warranting answer on reference.

Analysis: The question turned on the evidence and conduct of the parties and did not require application of any legal principle. The contention that the finding was perverse because certain material and a certificate were not considered was rejected, as the material had not been properly produced before the lower authorities and the certificate was at best a weak piece of evidence. The alleged omission did not establish perversity, and the inference drawn by the Tribunal from the price material could not convert the issue into a question of law.

Conclusion: The issue was one of fact, not law, and no answer to the reference was given.

---