Finding of fact on manufacture of gold jewellery barred any question of law and defeated the Revenue's reference request.

The Tribunal's conclusion that the assessee's firms purchased old gold ornaments and manufactured new gold jewellery at their premises, supported by vouchers showing making charges, weight, purity and wastage, was based on appreciation of evidence. The Revenue's claim that only polishing was done was not supported. Because the finding turned purely on facts, it did not give rise to any question of law, and the Revenue was not entitled to a reference on the claimed Wealth-tax Act exemption.

---

---

Issues: Whether the Appellate Tribunal's finding that the assessee's firms were engaged in the manufacture of new gold jewellery from old gold ornaments was a finding of fact giving rise to no question of law, and whether the Revenue was entitled to a reference on the assessee's claimed exemption under the Wealth-tax Act.

Analysis: The Tribunal found on the evidence that the firms in which the assessee was a partner purchased old gold ornaments, engaged goldsmiths at their premises, and manufactured new gold jewellery, with vouchers showing manufacture-related details such as making charges, weight, purity, and wastage. The Revenue's contrary assertion that only polishing was done was unsupported. As the Tribunal's conclusion rested on appreciation of facts and evidence, it was a pure finding of fact.

Conclusion: No question of law arose from the Tribunal's finding, and the Revenue's application for reference failed.

---