Interpretation of "other place" under tax exemption law turned fact-specific, so no referable question of law arose.

The expression "other place" in section 23(3) of the Income-tax Act was treated as wider than "other town", and the availability of the exemption depended on the facts of each case. On the facts stated, the assessee was required by reason of office to reside in an official residence at New Delhi while keeping his own residential house in Delhi vacant, so the proposed reference under section 256(2) raised no debatable question of law. No reference was therefore called for, and the request for reference failed.

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Issues: Whether a reference under section 256(2) of the Income-tax Act, 1961, was required on the question whether the assessee was entitled to exemption under section 23(3) of the Act.

Analysis: The assessee was required by reason of his office to reside in an official residence at New Delhi, while retaining his own residential house in Delhi vacant. The statutory expression "other place" was held to be wider than "other town", and the application of section 23(3) depended on the facts of the case. On the facts found, the answer to the proposed question was treated as self-evident and no debatable question of law arose warranting a reference.

Conclusion: No reference was called for under section 256(2); the assessee's claim for a reference failed.

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