Referral of Questions of Law not mandated where dispute is factual; requirement to state reasons treated as propriety, not mandamus remedy.

Whether an appellate officer was legally obliged to refer questions of law or to state detailed reasons was addressed by treating the disputed process as a statutory disposition rather than a referral. The analysis holds that the complaint primarily concerned factual evaluation and sufficiency of materials-matters outside the court's statutory jurisdiction to convert into questions of law. The obligation to set out detailed reasons was characterised as a matter of propriety, not a legally enforceable duty mandating mandamus. Result: mandamus was denied and the administrative disposal upheld.

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Issues: Whether the Commissioner of Income Tax was obliged to state a case or refer questions of law to the High Court under Section 66 and whether mandamus could be issued to require such a reference.

Analysis: The Bench's prior direction and its language indicate the High Court proceeded under the disposition mechanism of Section 66(5) rather than the referral-for-addition mechanism of Section 66(4). The Commissioner treated his reconsideration as a referred appeal and made a factual finding that there were materials justifying the Assistant Commissioner's enhancement. The petitioners challenged the absence of detailed reasons, asserting a general duty on appellate officers to state full grounds. The Court examined whether that complaint raised a question of law within its jurisdiction and concluded that the matter involved evaluation of facts and sufficiency of materials, matters beyond the High Court's jurisdiction under the statute. The Court further treated the obligation to set out detailed reasons as a matter of propriety rather than a legal requirement enforceable by mandamus.

Conclusion: Petition for mandamus dismissed; no question of law requiring the Commissioner to refer or state a case arose and the Commissioner's disposal in conformity with the Court's judgment stands.

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