Factual finding on sufficient cause for delayed wealth-tax returns did not raise a referable question of law.

The Tribunal's finding that the assessee had sufficient cause for delay in filing wealth-tax returns was treated as a factual determination based on the extension of time under the Board's circular and the assessee's belief that no taxable wealth existed. As no material distinction was shown between the two assessment years, the appellate appreciation of those facts was not displaced. On that basis, no referable question of law arose under section 27 of the Wealth-tax Act, 1957, and the reference applications were not maintainable.

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Issues: Whether the Tribunal's finding that the assessee had sufficient cause for delay in filing the wealth-tax returns gave rise to any referable question of law under section 27 of the Wealth-tax Act, 1957.

Analysis: The delay in filing the returns had been considered on the facts found by the appellate authorities, including the extension of time under the Board's circular and the assessee's belief that no taxable wealth existed. The conclusion that sufficient cause existed was treated as essentially factual. No material distinction was shown between the two assessment years to dislodge the Tribunal's reliance on its earlier order, and no legal question was demonstrated from the factual appreciation.

Conclusion: No question of law arose from the Tribunal's order, and the reference applications were not maintainable.

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