Weighted deduction apportionment under section 35B was treated as a factual finding, leaving no referable question of law.

Weighted deduction under section 35B for salary expenses was accepted in principle; the Revenue challenged only the Tribunal's 75% apportionment. That allocation was treated as a finding of fact, and the reference applications contained no allegation that it was unsupported by material, arbitrary, or perverse. In those circumstances, the controversy did not raise a referable question of law under section 256, and no statable question of law arose from the Tribunal's order.

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Issues: Whether any referable question of law arose from the Tribunal's order affirming allowance of 75% of the salary expenses as weighted deduction under section 35B of the Income-tax Act, 1961.

Analysis: The Revenue did not dispute the allowability of weighted deduction for salary expenses under section 35B; it disputed only the percentage at which the claim was allowed. The apportionment of the claim at 75% was treated as a finding of fact. The reference applications did not suggest that the finding was unsupported by material, arbitrary, or perverse. In the absence of any such allegation, the controversy did not give rise to a question of law capable of being referred under section 256.

Conclusion: No statable question of law arose from the Tribunal's order, and the reference applications were rejected.

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