Reference jurisdiction limits interference with factual findings where the Tribunal's view is supported by relevant material.

In reference jurisdiction under section 66(2), a High Court cannot disturb a Tribunal's factual conclusion merely because another view is possible. The Tribunal had evaluated the evidence and competing circumstances relating to the assessee's explanation for the source of funds, and its decision to cancel the addition was based on relevant material rather than conjecture. Since the finding represented a permissible view on the facts, the High Court upheld the cancellation of the addition in favour of the assessee.

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Issues: Whether the Tribunal was justified in cancelling the addition of Rs. 40,000 made in the assessee's assessment for the relevant assessment year.

Analysis: The Tribunal had considered all relevant material and the competing circumstances bearing on the assessee's explanation for the source of the funds. Its conclusion was reached after weighing the evidence on both sides and was not based on conjecture or surmise. In a reference under section 66(2), the High Court's jurisdiction was limited, and it could not reverse a conclusion that was a permissible view on the facts merely because another view was possible.

Conclusion: The Tribunal was justified in cancelling the addition, and the question was answered in the affirmative, in favour of the assessee.

Ratio Decidendi: In reference jurisdiction, a finding of fact based on appraisal of relevant material and representing a possible view cannot be interfered with merely because another conclusion may also be possible.

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