https://www.taxtmi.com/caselaws?id=20029 The Tribunal's deletion of both additions rested on clear findings of fact: the Revenue failed to link the seized paper with the assessee or the alleged investment, and the assessee's explanation of the investment source, including contribution by his wife, was accepted on evidence. Because the dispute was decided on appreciation of material rather than on interpretation of any statutory provision, no referable question of law arose. A Tribunal finding of fact is not open in reference unless unsupported by material or perverse, and no such defect was shown. The application under section 256(2) was therefore liable to be rejected. en-us Thu, 04 Nov 1993 00:00:00 +0530 Wed, 11 Nov 2009 12:02:35 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=20029 The Tribunal's deletion of both additions rested on clear findings of fact: the Revenue failed to link the seized paper with the assessee or the alleged investment, and the assessee's explanation of the investment source, including contribution by his wife, was accepted on evidence. Because the dispute was decided on appreciation of material rather than on interpretation of any statutory provision, no referable question of law arose. A Tribunal finding of fact is not open in reference unless unsupported by material or perverse, and no such defect was shown. The application under section 256(2) was therefore liable to be rejected. Case-Laws Income Tax Thu, 04 Nov 1993 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=20029