Factual appraisal of past income additions and bank deposits did not raise a referable question of law under income-tax procedure.

Estimated past additions to income and their use as a source for later bank deposits were treated as a factual accounting exercise, not a legal question requiring reference under section 256(2) of the Income-tax Act, 1961. The Tribunal compared earlier extra profit additions with the deposits, allowed deductions for marriage and domestic expenses, and found sufficient funds remained available to explain the deposits. The High Court held that no legal error was shown in this method of factual appraisal, so no referable question of law arose and the reference applications were rejected.

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Issues: Whether the Tribunal's finding that past estimated additions to income could be treated as available funds for explaining later bank deposits gave rise to a referable question of law under section 256(2) of the Income-tax Act, 1961.

Analysis: The Tribunal had examined the comparative figures of extra profit added over the years and the bank deposits, allowed deductions for marriage and domestic expenses, and found that a substantial amount remained available to the assessees for making the deposits. The Court treated this as an approach based on appraisal of facts and accounts. No legal error was shown in the Tribunal's method of relating earlier additions to later deposits, and the decision did not depend on any disputed principle of law requiring reference.

Conclusion: No question of law arose from the Tribunal's appellate decision, and the applications for reference were rightly rejected.

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