Duplicate reference questions and factual valuation disputes did not raise any referable question of law

No further reference was justified where the questions proposed were already comprehensively covered by the Tribunal's earlier reference on the same assessment year and identical controversy. The court held that duplicate reference questions do not arise when the earlier formulation is wide enough to cover all aspects. The valuation of ornaments was also held to be purely factual, because the authorities had assessed the valuers' reports and recorded findings in favour of the assessee, which the Tribunal affirmed. As the dispute turned on appreciation of evidence rather than a legal principle, no referable question of law arose and all reference applications were declined.

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Issues: (i) Whether further reference was warranted on questions already covered by the Tribunal's earlier reference. (ii) Whether the valuation of ornaments gave rise to any question of law.

Issue (i): Whether further reference was warranted on questions already covered by the Tribunal's earlier reference.

Analysis: The questions sought to be referred were the same as those already referred by the Tribunal for the relevant assessment year. Since the earlier referred questions were wide enough to cover all aspects, no separate or additional reference was justified on identical facts and the same legal controversy.

Conclusion: No further reference was warranted, and the issue was decided against the Revenue and in favour of the assessee.

Issue (ii): Whether the valuation of ornaments gave rise to any question of law.

Analysis: The valuation dispute turned on appreciation of evidence and factual assessment. The authorities had considered the valuers' reports, recorded a finding in favour of the assessee, and the Tribunal affirmed that finding on reconsideration. Such a determination did not raise any question of law.

Conclusion: The valuation of ornaments raised only a question of fact, not a referable question of law, and the issue was decided against the Revenue and in favour of the assessee.

Final Conclusion: All the applications for reference were declined, as no additional referable question of law arose on the facts.

Ratio Decidendi: Where a question is already comprehensively covered by an earlier reference, or where the dispute is purely factual such as valuation based on evidence, no further reference lies under the reference jurisdiction.

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