Substantial question of law absent where tax liability turned on Tribunal's factual finding about contractual water and sewerage charges.

The Tribunal's finding that water and sewerage charges were neither received nor receivable under the contract was treated as a factual determination based on the contractual terms and billing pattern. Those charges were held to be fixed by the municipal body for its own accounting purposes, not part of the bid price, and merely added and deducted in the bills. On that footing, the amounts did not form part of the contract value liable to composition tax under section 6A. The High Court held that the challenge raised no substantial question of law and that the reference application was therefore not maintainable.

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Issues: Whether the reference application disclosed any substantial question of law for consideration, or whether the proposed question was purely one of fact arising from the Tribunal's finding that the impugned water and sewerage charges were neither received nor receivable under the contract.

Analysis: The Tribunal had examined the contractual terms and the billing pattern and concluded that the water and sewerage charges were fixed by the municipal body for its own accounting purposes, were not part of the bid price, and were simultaneously added and deducted in the bills. On that basis, it held that the amounts were neither receivable nor received by the contractor and therefore did not form part of the contract value liable to composition tax under section 6A. The High Court accepted that the Tribunal had considered the matter threadbare and that the challenge turned entirely on the factual finding recorded by the Tribunal, not on any legal interpretation requiring reference.

Conclusion: No substantial question of law arose, and the reference application was not maintainable for adjudication on that basis.

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