Reference of questions of law allowed where identical facts were covered by an earlier High Court direction in a connected matter.

Identical facts involving the same assessee were governed by an earlier High Court direction requiring reference of questions of law in a connected matter. The Tribunal aligned the reframed questions in this application with those already directed to be referred, treating the controversy as covered by that prior order. The Revenue's reference application was therefore allowed and the questions of law were referred to the High Court.

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Issues: Whether the Revenue's reference application should be allowed and the reframed questions of law should be referred to the High Court.

Analysis: The present application arose out of identical facts involving the same assessee and had to be considered in the light of the earlier direction of the High Court requiring reference of questions of law in the connected matter. As the controversy was covered by that prior order, the Tribunal found it appropriate to align the questions raised in this application with the questions already directed to be referred.

Conclusion: The reference application was allowed and the questions of law were referred to the High Court.

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