Reference jurisdiction limits factual interference where concurrent findings are evidence-based and no legal infirmity is shown.

In reference jurisdiction under the Kerala Agricultural Income-tax Act, 1950, a High Court may interfere with concurrent factual findings only if they are perverse, unsupported by evidence, or based on irrelevant material or ignored relevant material. The assessing and appellate authorities had found that income from newly registered coffee area had not been disclosed and estimated taxable income on that basis. The Supreme Court held that the High Court upset those findings without identifying any legal error or evidentiary infirmity, so its order could not stand and the matter was remitted for fresh consideration.

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Issues: Whether the High Court was justified, in a reference under the Kerala Agricultural Income-tax Act, 1950, in upsetting concurrent factual findings of the assessing and appellate authorities without indicating any legal error or absence of evidence.

Analysis: The assessment authorities and the Tribunal had recorded findings that income from 60.79 acres of newly registered coffee area had not been disclosed and had estimated the taxable income on that basis. In reference jurisdiction, interference is confined to questions of law. A factual conclusion can be disturbed only where it is perverse, unsupported by evidence, or reached by ignoring relevant material or relying on irrelevant material. The High Court gave no discernible reason for holding the findings unsustainable and did not identify any legal infirmity in the evidence-based conclusions recorded below.

Conclusion: The High Court's order could not be sustained and the matter was remitted to the High Court for fresh consideration.

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