Jurisdiction to impose penalty depended on the date of reference, requiring a supplementary statement before reconsideration.

Jurisdiction to impose penalty depended on the date on which the Wealth-tax Officer referred the matter to the Inspecting Assistant Commissioner, because that factual date was material to determining competence. The court held that the reference could not be decided on the existing record without that date, and it required a supplementary statement of the case setting out the reference date. The reference was then directed to be taken up again after receipt of the supplementary statement.

---

---

Issues: Whether the date on which the Wealth-tax Officer referred the penalty matter to the Inspecting Assistant Commissioner was material to determine jurisdiction to impose penalty; and whether the reference could be decided without that factual date.

Outcome: The matter required a supplementary statement of the case stating the date of reference, and the reference was directed to be taken up again after receipt of that statement.

---