Bad-debt deduction remains a factual issue, and no referable question of law arose from the Commissioner's procedure.

A bad-debt claim was treated as a question of fact, including whether the debt was bad and when it became bad, and the Assistant Commissioner's findings on those facts were final. The Commissioner's refusal to hear the assessee again after obtaining a further report did not change the factual position or cause legal prejudice; at most it amounted to a procedural irregularity. On that basis, no referable question of law arose from the orders under Section 33 or Section 66(2), so reference was not justified and the answer was against the assessee.

---

---

Issues: Whether a question of law arose from the Commissioner's order so as to justify a reference under Section 66(2) of the Indian Income-tax Act, 1922, and whether the assessee was prejudiced by the procedure adopted in deciding the bad-debt claim.

Analysis: The controversy turned on whether the Commissioner's refusal to hear the assessee again after obtaining a further report, and his final rejection of the bad-debt deduction, disclosed any referable question of law. The assessee's claim had already been negatived on findings of fact by the Assistant Commissioner, who was the final authority on facts. The issue whether a debt is bad and when it became bad was treated as essentially factual. The later order did not alter the factual position to the assessee's prejudice, and the complaint at best disclosed only a procedural irregularity. No legal question emerged from the orders under Section 33 or Section 66(2).

Conclusion: No question of law arose for reference, and the answer was in the negative against the assessee.

---