Reference questions must independently require determination; explanatory or ancillary issues need not be separately stated for High Court reference.

In reference proceedings under section 27(3) of the Wealth-tax Act, questions that independently require determination may be stated for the High Court, but explanatory or merely argumentative questions subsumed within another issue need not be separately referred. On that basis, the questions concerning the discounted value of compensation and the Tribunal's year-wise percentage method were treated as fit for reference, while the additional questions were declined as non-independent or merely ancillary. The reference application therefore succeeded only in respect of the first two questions.

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Issues: (i) Whether questions Nos. 1 and 2 arising from the Tribunal's direction on valuation of compensation were fit to be referred to the High Court under section 27(3) of the Wealth-tax Act, 1957. (ii) Whether questions Nos. 3 and 4 were separately referable.

Issue (i): Whether questions Nos. 1 and 2 arising from the Tribunal's direction on valuation of compensation were fit to be referred to the High Court under section 27(3) of the Wealth-tax Act, 1957.

Analysis: The questions relating to the discounted value of compensation and the manner in which the Tribunal fixed year-wise percentages raised issues requiring reference. They were not treated as merely academic or unsubstantial, and the court directed that they be stated.

Conclusion: Questions Nos. 1 and 2 were held to be referable.

Issue (ii): Whether questions Nos. 3 and 4 were separately referable.

Analysis: Question No. 3 was considered explanatory in nature and question No. 4 was treated as merely argumentative and as an aspect of question No. 2. On that basis, no separate reference was warranted for either question.

Conclusion: Questions Nos. 3 and 4 were held not to be referable.

Final Conclusion: The reference application succeeded only to the extent of questions Nos. 1 and 2, while the remaining questions were declined.

Ratio Decidendi: In proceedings for reference, only questions that independently call for determination can be referred; explanatory or merely argumentative questions, including those subsumed within another referred question, need not be separately stated.

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