Unproved loan findings remained factual, and no referable question of law arose from the tribunal's decision.

A finding that loan amounts were unproved was treated as a factual determination based on appreciation of evidence, not a question of law. The further direction that the Income-tax Officer should decide in whose hands the income was assessable did not transform that factual conclusion into a referable legal issue. Since the dispute turned on whether the loans were genuine, and that issue was essentially factual, no question of law arose from the challenged orders and the petition was dismissed.

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Issues: Whether any question of law arose from the Tribunal's finding that the two loan amounts were unproved, so as to justify a reference.

Analysis: The Tribunal's conclusion that the loans were not genuine was based on appreciation of facts. The further direction that the Income-tax Officer should determine in whose hands the income was assessable did not convert that factual finding into a legal question. A finding on whether loans are proved or unproved is essentially factual, and no referable question of law arose from the orders under challenge.

Conclusion: No question of law arose; the petition was dismissed.

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