Bona fide belief in limitation matters may be factual, so no question of law arose for reference.

A limitation dispute based on bona fide belief was treated as a factual question because the finding depended on appreciation and interpretation of evidence. The Tribunal held that no question of law arose merely because the assessee claimed to have acted under a bona fide belief. The cited High Court rulings were distinguished on the basis that they arose from materially different factual and legal settings. On that reasoning, the reference application was held not maintainable.

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Issues: Whether a question of law arose for reference on the issue of limitation founded on bona fide belief.

Analysis: The finding on bona fide belief depended upon appreciation and interpretation of evidence and was therefore factual in nature. The Tribunal held that no question of law arose for reference merely because the limitation issue turned on whether the assessee acted under a bona fide belief. The cited High Court decisions were distinguished as arising in materially different factual and legal settings.

Conclusion: No question of law arose for reference on the limitation issue, and the reference application was not maintainable.

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