Fact-finding on ex parte assessment and opportunity to produce C forms did not raise a question of law.

Sufficiency of opportunity to produce C forms and the justification for an ex parte assessment were treated as fact-dependent questions. The Financial Commissioner, as the final fact-finding authority under the sales tax law, was competent to reach its own conclusion on those matters, and a challenge to that conclusion did not give rise to a question of law. On that basis, the request to draw up a statement of case and refer the matter to the High Court was refused.

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Issues: Whether any question of law arose from the order setting aside the ex parte assessment and remanding the matter for fresh assessment after giving the dealer an opportunity to produce C forms.

Analysis: The dispute turned on whether the dealer had been given sufficient opportunity and whether the ex parte assessment was justified. These matters depended on appreciation of the record and evidence. The Financial Commissioner was the last fact-finding authority under the applicable sales tax law and was competent to reach his own conclusion on sufficiency of opportunity. A challenge to that conclusion did not raise a question of law for reference.

Conclusion: No question of law arose from the impugned order, and the request to draw up a statement of case and refer the matter to the High Court was refused.

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