Concurrent factual findings on unexplained deposits did not raise a referable question of law under income-tax reference provisions.

Concurrent findings rejected the assessee's explanation for the deposits for lack of supporting material, and the source claim that the money came from the husband and mother was treated as a question of fact. As no cogent evidence established the stated source, the deposits were sustained as income from undisclosed sources. The High Court held that this factual determination did not give rise to a referable question of law under section 256(2) of the Income-tax Act, 1961, and the reference petition was not maintainable.

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Issues: Whether the Tribunal's finding sustaining the addition of deposits as income from undisclosed sources gave rise to a referable question of law under section 256(2) of the Income-tax Act, 1961.

Analysis: The explanation offered for the deposits was rejected by the assessing authority, the appellate authority, and the Tribunal for want of supporting material. The issue whether the assessee had satisfactorily traced the source of the money to the husband and mother was treated as one of fact. Since no cogent evidence was produced to establish the claimed source of the deposits, the concurrent finding that the amount was assessable as income from undisclosed sources did not present any legal question requiring reference.

Conclusion: No question of law arose for reference; the petition for reference was not maintainable.

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