Cash credit genuineness remained a factual issue, so no referable question of law arose from the Tribunal's findings.

Cash credits in the assessee-firm's books were treated as a question of fact because the Tribunal had found that the amounts were investments by bona fide persons and were satisfactorily explained. A legal question mentioned only incidentally in the course of factual findings did not, by itself, become a referable question of law under reference jurisdiction. The requests for reference were therefore rejected.

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Issues: Whether the Tribunal could be directed to state a question of law for the High Court where the dispute turned on the genuineness of cash credits and the Tribunal had recorded a factual finding that the credits belonged to bona fide investors.

Analysis: The dispute concerned the nature and source of credits standing in the assessee-firm's books. The Tribunal had already found, on the facts, that the amounts represented investments by other bona fide persons and were satisfactorily explained. A mere incidental discussion of a legal question while recording findings of fact did not by itself make that question one arising from the Tribunal's decision for reference under the relevant reference jurisdiction.

Conclusion: The matter was treated as one of fact, no referable question of law was found, and the requests for reference were rejected.

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