Concealment finding on land sale consideration raised no referable question of law, so penalty basis remained undisturbed.

No referable question of law arose from the Tribunal's factual finding that the assessee had concealed income in relation to the sale consideration of land. The High Court was correct in treating the proposed issues as questions of fact and in refusing to call for a reference. On that basis, the concealment finding supporting penalty under section 271(1)(c) of the Income-tax Act, 1961, was left undisturbed.

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Issues: Whether any referable question of law arose from the Tribunal's finding that the assessee had concealed income in relation to the sale consideration of land, so as to justify penalty under section 271(1)(c) of the Income-tax Act, 1961.

Analysis: The Tribunal had reached a finding of concealment on the basis of the material on record. The High Court declined to call for reference on the view that the proposed questions were questions of fact. In the appeal, it was held that the High Court was right, because no question of law arose from the Tribunal's factual determination.

Conclusion: No referable question of law arose; the refusal to call for a reference was correct, and the penalty finding based on concealment stood.

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