Accepted assessee explanation as material evidence; absence of further corroboration did not create a question of law.

The Tribunal's finding that the assessee had purchased gold in 1918 and sold it in the relevant year was supported by material because it accepted the assessee's explanation on the basis of his statement, surrounding conduct and past history. Once that version was believed, the statement itself constituted evidentiary support for the factual conclusion, and the absence of further corroboration did not by itself raise a question of law. The High Court was therefore wrong to interfere on that basis, and the answer to the reference was in favour of the assessee.

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Issues: Whether there was material before the Tribunal to support the finding that the assessee had purchased gold in 1918 and sold it during the relevant year.

Analysis: The Tribunal accepted the assessee's explanation on the basis of his statement and surrounding conduct and past history. Once that statement was believed, it constituted material on which the finding could rest. A mere demand for additional corroboration did not convert the issue into a question of law, because the acceptance of the assessee's version itself furnished evidentiary support for the conclusion reached by the Tribunal.

Conclusion: The finding was supported by material and the High Court was wrong in holding otherwise.

Final Conclusion: The answer to the reference was in favour of the assessee and the appeal succeeded.

Ratio Decidendi: Where a tribunal believes an assessee's explanation, that accepted statement is itself material evidence sufficient to support the finding of fact and no further question of law arises merely because corroboration is absent.

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