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    <description>A reference under section 256(2) was refused because the Tribunal&#039;s view on penalty under section 273 rested on appreciation of evidence, not on any independent question of law. The dispute depended on whether the assessee&#039;s additional income disclosure was voluntary or whether concealment had been proved, and the Department produced no material to establish concealment or coercion. As the finding was factual and the legal issue was already settled in principle, no referable question of law arose and the request to state a case was rejected.</description>
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      <description>A reference under section 256(2) was refused because the Tribunal&#039;s view on penalty under section 273 rested on appreciation of evidence, not on any independent question of law. The dispute depended on whether the assessee&#039;s additional income disclosure was voluntary or whether concealment had been proved, and the Department produced no material to establish concealment or coercion. As the finding was factual and the legal issue was already settled in principle, no referable question of law arose and the request to state a case was rejected.</description>
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