Cash basis accounting and received interest rendered the reference unnecessary, so no merits opinion was given.

The reference was disposed of without an opinion on the merits because the framed question did not arise once the Tribunal found that the assessee kept accounts on cash basis and that the interest was actually received in the relevant accounting year. On that factual basis, the court treated the reference as unnecessary for decision and declined to answer the question referred.

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Outcome: The reference was disposed of without an answer on the merits, as the court found that the question framed for opinion did not arise in view of the Tribunal's finding that the assessee maintained accounts on cash basis and the interest had been received in the relevant accounting year.

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